Penalty u/s 271G - under TNMM adopted by the assessee, the profit of the international transaction has...

Penalty u/s 271G - under TNMM adopted by the assessee, the profit of the international transaction has to be furnished, whereas the assessee has only furnished the entity level margins which consists of overall profits on AE and significant non non-AE transactions - reasonable cause for non-compliance - In the interest of justice, we vacate the order of learned CIT(A) and set aside the issue to the learned CIT(A). - AT .....

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