https://www.taxtmi.com/caselaws?id=468160 Penalty under section 271(1)(c) was not leviable on transfer pricing adjustment for corporate guarantee fee or on disallowance of education cess and secondary higher education cess. The corporate guarantee fee addition had been sustained in quantum only on an estimated arm's length price basis and was treated as debatable, so there was no material showing concealment of income or furnishing of inaccurate particulars. For the cess disallowance, the relevant facts had been fully disclosed, and mere non-pressing of the quantum ground did not by itself justify penalty. The penalty deletion was upheld. en-us Wed, 16 Apr 2025 00:00:00 +0530 Sat, 18 Apr 2026 13:56:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468160 Penalty under section 271(1)(c) was not leviable on transfer pricing adjustment for corporate guarantee fee or on disallowance of education cess and secondary higher education cess. The corporate guarantee fee addition had been sustained in quantum only on an estimated arm's length price basis and was treated as debatable, so there was no material showing concealment of income or furnishing of inaccurate particulars. For the cess disallowance, the relevant facts had been fully disclosed, and mere non-pressing of the quantum ground did not by itself justify penalty. The penalty deletion was upheld. Case-Laws Income Tax Wed, 16 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468160