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

No Penalty for Treating Expense Reimbursement as Fees for Technical Services u/s 271(1)(c) of Income Tax Act.

October 17, 2022

Case Laws Income Tax AT

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

No Penalty for Treating Expense Reimbursement as Fees for Technical Services u/s 271(1)(c) of Income Tax Act.

October 17, 2022

Case Laws Income Tax AT

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