https://www.taxtmi.com/highlights?id=96930 Penalty under section 271(1)(c) was contested where taxability of interest and commitment fees turned on interpretation of the India Germany DTAA and whether a representative office constituted a Permanent Establishment; AO taxed receipts at 40% but Tribunal treated them under Article 11 at 10%. The CIT(A) and Tribunal found the addition arose from the assessee's voluntary disclosures and a bona fide difference of opinion, invoking Reliance Petroproducts that an unsustainable claim alone does not constitute furnishing inaccurate particulars. Consequently no penalty was warranted and the appellant's appeal was allowed. en-us Mon, 16 Feb 2026 10:13:57 +0530 Mon, 16 Feb 2026 10:13:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=96930 Penalty under section 271(1)(c) was contested where taxability of interest and commitment fees turned on interpretation of the India Germany DTAA and whether a representative office constituted a Permanent Establishment; AO taxed receipts at 40% but Tribunal treated them under Article 11 at 10%. The CIT(A) and Tribunal found the addition arose from the assessee's voluntary disclosures and a bona fide difference of opinion, invoking Reliance Petroproducts that an unsustainable claim alone does not constitute furnishing inaccurate particulars. Consequently no penalty was warranted and the appellant's appeal was allowed. Highlights Income Tax Mon, 16 Feb 2026 10:13:57 +0530 https://www.taxtmi.com/highlights?id=96930