https://www.taxtmi.com/caselaws?id=799215 Section 271(1)(c), read with Explanation 7, does not treat a bona fide transfer-pricing or deduction claim as furnishing inaccurate particulars merely because an adjustment or disallowance arises. Export benchmarking, comparable selection, loan terms, interest-rate methodology and CUP-based arm's-length computations must demonstrate good faith, due diligence and full disclosure of material facts. A leave-encashment claim founded on prevailing judicial directions and a documented legal-fee claim in computing capital gains similarly do not warrant penalty where the claims and supporting material are disclosed. Deletion of the underlying quantum addition removes the basis for penalty on that claim. en-us Thu, 27 Aug 2026 00:00:00 +0530 Fri, 18 Sep 2026 07:32:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799215 Section 271(1)(c), read with Explanation 7, does not treat a bona fide transfer-pricing or deduction claim as furnishing inaccurate particulars merely because an adjustment or disallowance arises. Export benchmarking, comparable selection, loan terms, interest-rate methodology and CUP-based arm's-length computations must demonstrate good faith, due diligence and full disclosure of material facts. A leave-encashment claim founded on prevailing judicial directions and a documented legal-fee claim in computing capital gains similarly do not warrant penalty where the claims and supporting material are disclosed. Deletion of the underlying quantum addition removes the basis for penalty on that claim. Case-Laws Income Tax Thu, 27 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799215