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2020 (10) TMI 719 - AT - Income TaxLevy of penalty u/s 271AA - Assessee did not file Form 3CEB before 30.09.2011 for A.Y. 2011-12, being the specified date for its filing but the same was filed only on 18.07.2013 after the fact of non-compliance was confronted to assessee - No information about the international transaction in its transfer pricing report - CIT-A deleted the addition - HELD THAT:- CIT(A) while deleting the penalty has given a finding that assessee has kept and maintained the information about the international transactions, the discussion of which is also in the Transfer Pricing Report which was submitted to the TPO during the assessment proceedings. CIT(A) thus concluded that the assessee was maintaining the information and documents as prescribed under the law regarding international transactions and that assessee has not failed in reporting any international transactions. Before us, Revenue has not pointed to any fallacy in the findings of CIT(A). We further find that the ratio of the decision in the case of Mak Data Pvt. Ltd [2013 (11) TMI 14 - SUPREME COURT] relied before us by Revenue is not applicable to the facts of the present case. - Decided in favour of assessee.
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