https://www.taxtmi.com/caselaws?id=788799 Penalty under section 271(1)(c) is discussed as applying to additions and disallowances where the assessee cannot show bona fide explanation, due diligence, or factual substantiation. The note covers transfer pricing adjustments, GDR issue expenses treated as non-bona fide capital-related claims, unsupported miscellaneous or MODVAT expenses, and statutory contribution defaults under section 36(1)(va). It also addresses unreported foreign exchange gains and TDS reconciliation differences, where omission from the return was not credibly explained. By contrast, a foreign exchange derivative loss based on hedging transactions is described as a bona fide business claim, and the section 40(a)(ia) matter is linked to the outcome of de novo quantum proceedings. en-us Tue, 24 Mar 2026 00:00:00 +0530 Fri, 27 Mar 2026 10:49:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=788799 Penalty under section 271(1)(c) is discussed as applying to additions and disallowances where the assessee cannot show bona fide explanation, due diligence, or factual substantiation. The note covers transfer pricing adjustments, GDR issue expenses treated as non-bona fide capital-related claims, unsupported miscellaneous or MODVAT expenses, and statutory contribution defaults under section 36(1)(va). It also addresses unreported foreign exchange gains and TDS reconciliation differences, where omission from the return was not credibly explained. By contrast, a foreign exchange derivative loss based on hedging transactions is described as a bona fide business claim, and the section 40(a)(ia) matter is linked to the outcome of de novo quantum proceedings. Case-Laws Income Tax Tue, 24 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=788799