https://www.taxtmi.com/highlights?id=98401 Once the jurisdictional High Court had admitted the assessee's quantum appeal on substantial questions of law concerning the transfer pricing addition, the underlying addition had not attained finality and remained debatable. In that situation, the Tribunal applied the principle that a debatable claim does not by itself establish concealment of income or furnishing of inaccurate particulars. Penalty under section 271(1)(c) was therefore held not leviable, and the deletion of penalty was upheld. en-us Fri, 03 Apr 2026 08:49:32 +0530 Fri, 03 Apr 2026 08:49:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=98401 Once the jurisdictional High Court had admitted the assessee's quantum appeal on substantial questions of law concerning the transfer pricing addition, the underlying addition had not attained finality and remained debatable. In that situation, the Tribunal applied the principle that a debatable claim does not by itself establish concealment of income or furnishing of inaccurate particulars. Penalty under section 271(1)(c) was therefore held not leviable, and the deletion of penalty was upheld. Highlights Income Tax Fri, 03 Apr 2026 08:49:32 +0530 https://www.taxtmi.com/highlights?id=98401