Penalty u/s 271(1)(c) - TP Adjustment - it is a debatable issue whether reimbursement of expenses...

Penalty u/s 271(1)(c) - TP Adjustment - it is a debatable issue whether reimbursement of expenses qualifies as FTS and there are various decisions which have held that reimbursement of expenses does not qualify as FTS. Accordingly, we are of the considered view that no penalty can be levied u/s 271(1)(c) of the Act on account of treating reimbursement of expenses as FTS. - AT .....

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