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2018 (8) TMI 1137 - DELHI HIGH COURTLevy of penalty 271(1)(c) - concealment of income - failure to correctly compute arm’s length price of international transactions between the respondent-assessee and its holding company - question of bona fides of the explanation of the respondent-assessee and whether exclusion of the internal comparable was after due diligence. Held that:- The Tribunal has duly applied its mind to the relevant aspect of good faith and due diligence. The Tribunal has held that the respondent-assessee had been able to discharge the onus placed upon them in terms of Explanation 7 to Section 271(1)(c) of the Act and show that their stand and stance in not taking into consideration the internal transaction was in good faith and they had acted with due diligence. These findings of the Tribunal in the present case are factual and clearly plausible and reasonable. No penalty - Decided against the revenue.
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