https://www.taxtmi.com/caselaws?id=471849 Penalty under Section 271(1)(c) was unsustainable because most underlying additions had been deleted in quantum proceedings, while the surviving corporate-guarantee adjustment involved a debatable issue over whether it constituted an international transaction and an estimated arm's-length rate. The remaining expenditure disallowance relating to exempt income was substantially reduced and was formula-based and notional. These adjustments, without more, did not establish concealment of income or furnishing of inaccurate particulars; deletion of the penalty was therefore upheld. en-us Mon, 17 Jan 2022 00:00:00 +0530 Mon, 21 Sep 2026 10:30:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=471849 Penalty under Section 271(1)(c) was unsustainable because most underlying additions had been deleted in quantum proceedings, while the surviving corporate-guarantee adjustment involved a debatable issue over whether it constituted an international transaction and an estimated arm's-length rate. The remaining expenditure disallowance relating to exempt income was substantially reduced and was formula-based and notional. These adjustments, without more, did not establish concealment of income or furnishing of inaccurate particulars; deletion of the penalty was therefore upheld. Case-Laws Income Tax Mon, 17 Jan 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=471849