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2013 (1) TMI 183 - AT - Income TaxPenalty u/s 271BA – Transfer pricing – Assessee failed to furnish Transfer pricing report u/s 92E by due date - form No. 3CEB - Under Rule 10E - Rule 12(2) of the Income-tax Rules, 1962 – Held that:- As per Sec. 92E it is clear that the report in Form 3CEB is to be filed by the specified date i.e. due date for filing the return. Nowhere in sec. 92E or Rule 10E it is mentioned that such report should be annexed with return of income. As per Rule 12(2), the return of income/Fringe Benefits shall not be accompanied by report of Audit. The report in form 3CEB from an accountant is not a report of audit. It is a report in respect of international transaction certifying the claim of the assessee. Therefore, the contention of the assessee that return of income in electronic form was not to accompany the report in Form 3CEB is not correct. In favour of revenue
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