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2021 (2) TMI 1132 - AT - Income TaxPenalty u/s 271G - assessee failed to furnish documents as required under the Rule 10D(1) and sub-section (3) of the section 92D in respect of the international transactions entered into by it - HELD THAT:- Respectfully follow the view taken by the Tribunal in the case of Navinchandra Exports Pvt. Ltd. [2017 (11) TMI 1307 - ITAT MUMBAI] wherein it was observed that considering the practical difficulties involved in furnishing the segmental details of AE transactions and non-AE transactions in the diamond industry, penalty under Sec. 271G could not be justifiably imposed. Before parting, we may herein observe, that the Tribunal in its aforesaid order had observed that considering the reasonable cause for non-furnishing of the segmental details of the AE transactions and non-AE transactions because of the peculiar nature of the trade in diamond industry, penalty u/s. 271G even otherwise could not have been imposed as per the mandate of Sec. 273B. No infirmity emerges from the order of the CIT(A) who had rightly vacated the penalty imposed by the TPO under Sec. 271G - Decided against revenue.
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