https://www.taxtmi.com/caselaws?id=764835 Where the assessee's business model and receipt stream remained unchanged across years, the Tribunal applied tax certainty and consistency and treated the existing MAP resolution as the proper basis for assessment, with the income for the year directed to be taxed accordingly. On penalty, the Tribunal held that section 271(1)(c) was not attracted where the assessee had disclosed all material facts and only advanced a bona fide legal claim that the advertisement and distribution receipts were not taxable in the manner adopted by the Assessing Officer; a rejected claim on a debatable issue did not, by itself, amount to concealment or furnishing inaccurate particulars. en-us Tue, 31 Dec 2024 00:00:00 +0530 Sat, 18 Jan 2025 10:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=764835 Where the assessee's business model and receipt stream remained unchanged across years, the Tribunal applied tax certainty and consistency and treated the existing MAP resolution as the proper basis for assessment, with the income for the year directed to be taxed accordingly. On penalty, the Tribunal held that section 271(1)(c) was not attracted where the assessee had disclosed all material facts and only advanced a bona fide legal claim that the advertisement and distribution receipts were not taxable in the manner adopted by the Assessing Officer; a rejected claim on a debatable issue did not, by itself, amount to concealment or furnishing inaccurate particulars. Case-Laws Income Tax Tue, 31 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=764835