https://www.taxtmi.com/caselaws?id=753716 ITAT Bangalore held that penalty under sections 271(1)(c) or 270A was not justified where assessee failed to offer secondment receipts in original returns but later disclosed them during reassessment proceedings. The tribunal found assessee's conduct bonafide, noting contradictory judicial decisions on taxability of employee secondment reimbursements created reasonable doubt. Assessee had disclosed receipts in Form 3CB and voluntarily offered them for taxation during proceedings. Karnataka HC precedent in Abbey Business Services supported assessee's position that secondment reimbursements don't constitute fees for technical services. No concealment of income or furnishing of inaccurate particulars established. Penalty deleted in favor of assessee. en-us Mon, 20 May 2024 00:00:00 +0530 Sat, 08 Jun 2024 09:05:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=753716 ITAT Bangalore held that penalty under sections 271(1)(c) or 270A was not justified where assessee failed to offer secondment receipts in original returns but later disclosed them during reassessment proceedings. The tribunal found assessee's conduct bonafide, noting contradictory judicial decisions on taxability of employee secondment reimbursements created reasonable doubt. Assessee had disclosed receipts in Form 3CB and voluntarily offered them for taxation during proceedings. Karnataka HC precedent in Abbey Business Services supported assessee's position that secondment reimbursements don't constitute fees for technical services. No concealment of income or furnishing of inaccurate particulars established. Penalty deleted in favor of assessee. Case-Laws Income Tax Mon, 20 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=753716