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2018 (7) TMI 2099 - HC - Income TaxPenalty u/s 271G - failure to produce the documents, which are required to be mentioned under Section 92D(3) with regard to the international transactions - HELD THAT:- When the learned Tribunal was satisfied that there is substantial compliance of Section 92CA(3) of the Income Tax Act and when the Gross Profit of the assessee had increased from 7.42% for Assessment Year 2010-11 to 8.71% for the year under consideration, the Net Profit had also witnessed growth from 3.9% to 4.9% and looking to the business of the assessee in diamond, both the learned CIT(A) as well as the learned Tribunal have rightly observed and held that the TPO was not justified in levying the penalty under Section 271G of the Income Tax Act. We are in complete agreement with the view taken by the learned Tribunal. The findings of the fact recorded by the learned Tribunal are on appreciation of material on record. No substantial question of law arises.
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