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2018 (6) TMI 1098 - AT - Income TaxPenalty levied u/s 271AA and 271G - failure to keep and maintain information and documents as required under Sub Sections (1) and (2) of Section 92D and failure to furnish such information and documents - Contention of the assessee is that it had followed cost plus method in its transfer pricing study and therefore it was not required to maintain and produce data regarding comparables - Held that:- Section 271AA and Section 271G of the Act were enacted only for the purpose of penalizing the defaults of the nature committed by the assessee. No doubt Section 273B mandates that penalty under Sections 271AA and 271G of the Act are not imposable if the assessee proves that there was a reasonable cause for failure. However, assessee before us in our opinion has not been able to show any reasonable cause for not complying with Rules nor for its failure to produce information called for by the ld. TPO. In the circumstances, we are of the opinion that levy of penalty under Sections 271AA as well as 271G of the Act were justified. We do not find any reason to interfere with the orders of the lower authorities. - Decided against assessee
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