High Court Deletes Penalty u/s 271(1)(c) in Transfer Pricing Case Due to Debatable Base Erosion Theory Issue.

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....Penalty u/s. 271(1)(c) - Transfer pricing adjustment - Debatable issue - Base Erosion Theory - Reading a particular paragraph of the observations of the AO’s order reproduced by the CIT(A) itself would indicate that there were two views possible and that the issue was debatable. - Penalty was rightly deleted - HC....