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 2022 Year 2022 This

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

Income Tax

October 17, 2022

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

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. 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)...

  3. 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...

  4. TP adjustment on account of reimbursement of seafarer expenses - Revenue has only doubted the genuineness of the alleged reimbursement of expenses made by the assessee...

  5. 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

  6. 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...

  7. 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...

  8. 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...

  9. Penalty u/ s 271(1)(c) - Disallowance on account of personnel expenses, operative expenses and finance expenses - it a “mere disallowance” of an expense does not warrant...

  10. Penalty u/s 271(1)(c) - Defective notice u/s 274 - The notice u/s. 274 r.w.s. 271(l)(c) of the Act were issued without striking off the irrelevant portion of the limb...

  11. Transfer Pricing Adjustments on Corporate Guarantee Charges, Interest on Optionally Convertible Loans (OCL), and Reimbursement of Expenses. - The Tribunal found that...

  12. Levy of penalty u/s 271(1)(c) - deduction claimed u/s 80IA - there being no factual basis for establishing that the expenses needed to be allocated and the expenses so...

  13. Penalty u/s.271(1)(b) - no compliance to notice u/s 142(1) - The AO levied the penalty for non-compliance of notice dated 13.06.2016, however, there is no reference of...

  14. Levy penalty u/s 271(1)(c) - since no specific satisfaction has been recorded by the Ld. Assessing Officer either in the body of the assessment order or in the show...

  15. Penalty u/s.271(1)(c) - Nature of interest income - capital receipt or revenue receipt - This being a highly debatable issue and once there is a debate as assessee’s...

 

Quick Updates:Latest Updates