Tax Management India. Com
Law and Practice  :  Digital eBook
Research is most exciting & rewarding
  TMI - Tax Management India. Com
Follow us:
  Facebook   Twitter   Linkedin   Telegram
Income Tax - Highlights / Catch Notes

Home Highlights October 2023 Year 2023 This

Penalty u/s. 271(1)(c) - Transfer pricing adjustment - Debatable ...

October 30, 2023

Case Laws     Income Tax     HC

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

View Source

 


 

You may also like:

  1. Penalty u/s 271(1)(c) - addition on account of Transfer Pricing adjustment relating to payment of commission - it is evident that these are debatable issues - In any...

  2. This case deals with the levy of penalties u/ss 271AAA and 271(1)(c) of the Income Tax Act in relation to various additions made to the assessee's income based on seized...

  3. 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...

  4. Penalty levied u/s 271(1)(c) - addition u/s 68 - the entire addition itself becomes debatable one. It is well settled proposition of law that the penalty u/s 271(1)(c)...

  5. Penalty u/s 271(1)(c) for furnishing inaccurate particulars of income - adjustment made u/s 92CA - penalty levied u/s 271(1)(c) on the adjustment made u/s 92CA is not...

  6. Penalty levied u/s 271(1)(c) - Transfer pricing adjustment - assessee advanced interest free loan to its AE - The Tribunal noted that the assessee had disclosed all...

  7. Imposition of penalty u/s 271(1)(c) of the Income Tax Act for two types of additions: (1) the addition made u/s 50C on the difference between stamp duty value and sale...

  8. Penalty u/s 271(1)(c) - non-compliance of notice issues - if the quantum proceedings itself are declared to be bad in law and quashed , then any non compliance on the...

  9. Penalty levied u/s 271(1)(b) - failure to comply with the notices issued by the A.O u/s 142(1) - the non-compliance on the part of the assessee is due to the reason of...

  10. Penalty u/s 271(1)(c) - Transfer Pricing adjustment made - applying the analysis of the term ‘good faith’ and ‘due diligence’ we are of the considered view that in the...

  11. Penalty u/s 271(1)(c) - As a matter of fact the notice issued u/s 274 read with section 271 of the Act itself was ambiguous as it did not make it clear as to under which...

  12. Deletion of penalty u/s 271(1)(c) - Issues on basis of which ALP shown by the assessee has been rejected are debatable - No penalty - AT

  13. Penalty proceedings u/s 271(1)(c) - Assessee company failed to provide bonafide explanation for inflated expenses claimed in revised return, contrary to audited...

  14. Transfer pricing adjustment - interest free advances granted by the assessee to its Indian AE - base erosion theory - Tribunal rejected the the contention of the...

  15. The Assessing Officer (AO) consciously deleted irrelevant portions from the show cause notice, mentioning only the charge of furnishing inaccurate particulars of income....

 

Quick Updates:Latest Updates