https://www.taxtmi.com/caselaws?id=752048 Penalty under section 271(1)(c) was held unsustainable where the assessee had fully disclosed interest-free loans advanced to an associated enterprise and explained that the funds came from own resources as start-up support or as equity-like investment. The transfer pricing documentation contained the relevant particulars, and the explanation was not found false. In those circumstances, a sustained transfer pricing adjustment on its own did not establish concealment of income or furnishing of inaccurate particulars under Explanation 7. The penalty was deleted because the revenue had not shown lack of bona fides in the assessee's explanation. en-us Tue, 30 Apr 2024 00:00:00 +0530 Thu, 02 May 2024 08:37:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=752048 Penalty under section 271(1)(c) was held unsustainable where the assessee had fully disclosed interest-free loans advanced to an associated enterprise and explained that the funds came from own resources as start-up support or as equity-like investment. The transfer pricing documentation contained the relevant particulars, and the explanation was not found false. In those circumstances, a sustained transfer pricing adjustment on its own did not establish concealment of income or furnishing of inaccurate particulars under Explanation 7. The penalty was deleted because the revenue had not shown lack of bona fides in the assessee's explanation. Case-Laws Income Tax Tue, 30 Apr 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=752048