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2018 (11) TMI 1594 - AT - Income TaxPenalty u/s 271G - contravention to the provision of section 92D(3) - reasonable cause - assessee failed to furnish documentation as required under the rule 10D(1) and sub section (3) of the sec 92D in respect of the international transactions entered into by it - whether benchmarking of the entity level profit by the assessee cannot substitute the requirement of benchmarking of the international transactions to determine the arm’s length price? - HELD THAT:- We are of the view that the co-ordinate Bench has elaborately dealt with this issue and finally held that the assessee has substantially complied with the directions of the TPO and placed on record the requisite information as observed by CIT(A). The Revenue could not dislodge the findings of CIT(A). Hence, according to us, there is a reasonable cause in not complying with the provisions of section 92D(3) of the Act. Respectfully, following the co-ordinate Bench decision in the case of Dilipkumar V. Lakhi [2018 (8) TMI 1778 - ITAT MUMBAI] we confirm the order of CIT(A) and dismiss this appeal of Revenue.
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