Inaccurate-particulars penalties fail where transfer-pricing documentation shows good faith and due diligence, and underlying capital-gains additions are deleted.

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....Penalty for furnishing inaccurate particulars does not arise merely because a transfer-pricing comparable is rejected or an interest rate on an associated-enterprise loan is recomputed, where prescribed documentation and benchmarking demonstrate good faith and due diligence in determining the arm's length price. A leave-encashment provision claimed after payment of tax pursuant to an Apex Court stay order did not warrant penalty. Penalty on legal fees claimed in computing capital gains also lacked basis where supporting transfer documents and expenditure details were furnished and the underlying quantum addition was deleted. Penalty deletions were sustained for the transfer-pricing adjustments and disallowances.....