Penalty u/s 271(1)(c) - the proposition suggesting to read the ...

Income Tax

July 16, 2022

Penalty u/s 271(1)(c) - the proposition suggesting to read the mandate of copyright royalty cases in the context of industrial royalty cases is grossly misconceived. - The mere fact that an assessee has not challenged the addition does not per se lead to imposition or confirmation of penalty u/s.271(1)(c) of the Act thereon. The relevant facts and circumstances of the case need to be viewed independently for the purpose of penalty, which is distinct proceeding. Amongst others, it is a well settled proposition that penalty cannot be imposed on a debatable issue. - AT

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Penalty u/s 271(1)(c) - the proposition suggesting to read the ...

Income Tax

July 16, 2022

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