https://www.taxtmi.com/caselaws?id=365665 The High Court upheld the Tribunal's decision to delete the penalty for concealment of income under Section 271(1)(c) of the Income Tax Act, 1961. The Tribunal found the addition based on the difference in arm's length price to be debatable, thus not attracting the penalty. The respondent-assessee justified excluding an internal comparable transaction in the application of the Comparable Uncontrolled Price method due to its isolated nature. The Tribunal concluded that the respondent-assessee acted in good faith and with due diligence, meeting the requirements of Explanation 7 to Section 271(1)(c). The appeal by the Revenue was dismissed, with no costs awarded. en-us Fri, 03 Aug 2018 00:00:00 +0530 Mon, 10 Dec 2018 16:02:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=365665 The High Court upheld the Tribunal's decision to delete the penalty for concealment of income under Section 271(1)(c) of the Income Tax Act, 1961. The Tribunal found the addition based on the difference in arm's length price to be debatable, thus not attracting the penalty. The respondent-assessee justified excluding an internal comparable transaction in the application of the Comparable Uncontrolled Price method due to its isolated nature. The Tribunal concluded that the respondent-assessee acted in good faith and with due diligence, meeting the requirements of Explanation 7 to Section 271(1)(c). The appeal by the Revenue was dismissed, with no costs awarded. Case-Laws Income Tax Fri, 03 Aug 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=365665