https://www.taxtmi.com/caselaws?id=471783 Penalty for concealment or furnishing inaccurate particulars cannot rest solely on a transfer-pricing adjustment where the taxpayer disclosed international transactions, and the transactional net margin method and comparables were accepted. Rejection of claimed adjustments in the transfer-pricing study, followed by estimated attribution of expenses to associated-enterprise transactions without a corresponding adjustment for non-associated-enterprise expenditure, does not establish false or concealed particulars. As penalty proceedings are independent of assessment proceedings, an estimated or ad hoc addition without a specific finding of concealment or inaccurate particulars does not sustain penalty under section 271(1)(c). en-us Fri, 22 Sep 2023 00:00:00 +0530 Thu, 17 Sep 2026 17:56:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=471783 Penalty for concealment or furnishing inaccurate particulars cannot rest solely on a transfer-pricing adjustment where the taxpayer disclosed international transactions, and the transactional net margin method and comparables were accepted. Rejection of claimed adjustments in the transfer-pricing study, followed by estimated attribution of expenses to associated-enterprise transactions without a corresponding adjustment for non-associated-enterprise expenditure, does not establish false or concealed particulars. As penalty proceedings are independent of assessment proceedings, an estimated or ad hoc addition without a specific finding of concealment or inaccurate particulars does not sustain penalty under section 271(1)(c). Case-Laws Income Tax Fri, 22 Sep 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=471783