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2016 (4) TMI 947 - AT - Income TaxPenalty U/s 271AA - assessee failed to maintain the record as required U/s 92D of the I.T. Act read with rule 10D of the I.T. Rules - CIT(A) deleted the penalty - Held that:- The assessee disclosed international transaction made with AE. The Tribunal had decided that no upward adjustment is required in the ALP disclosed by the assessee. Whatever information asked to supply by the TPO had been furnished before him i.e. nine comparable companies data were furnished out of which the ld TPO had selected five companies. The ld DR had not controverted that the assessee had not provided similar services during the year under consideration as provided in F.Y 2004-05, therefore, comparable companies applied for F.Y. 2004-05 are relevant to the transactions made during the F.Y. 2005-06, which was also updated by the appellant. Accordingly, we uphold the order of the ld CIT(A). - Decided in favour of assessee
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