9911796707
TMI Blog2022 (8) TMI 900X X X X Extracts X X X X X X X X Extracts X X X X ..... ri V. K. Singh , Sr. DR Respondent by : Shri S. N. Soparkar , AR & Parin Shah , AR ORDER PER SUCHITRA KAMBLE , JUDICIAL MEMBER : This appeal is filed by the Revenue against the order dated 29.07.2019 passed by the CIT(A)-12, Ahmedabad for the Assessment Year 2014-15. 2. The Revenue has raised the following grounds of appeal: "1 The ld. CIT(A) has erred in law and on facts in deleting the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... matter was recalled to Transfer Pricing Officer for determining Arm's Length Price (ALP) of such transaction. There is an observation by the Assessing Officer that the assessee revised its return of income due to Specified Domestic Transaction but did not file the revised Specified Domestic Transaction in Form No.3CEB. Accordingly, the assessee was provided the opportunity to explain as to why pe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the penalty order, the assessee filed appeal before the CIT(A). The CIT(A) allowed the appeal of the assessee. 5. The Ld. DR submitted that the CIT(A) failed to appreciate the fact that the revised form No. 3CEB was not filed online by the assessee thereby specifying revised Domestic Transaction. Thus, the assessee is liable to pay penalty under Section 271G of the Act as the requirement under S ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... thin a period of thirty days or the extended period, penalty imposed under Section 271G is unsustainable. 7. We have heard both the parties and perused all the relevant material available on record. It is pertinent to note that the revised Form No.3CEB dated 18.03.2016 was filed by the assessee related to claim under Section 80IA of the Act. The penalty order under Section 271G has stated that th ..... X X X X Extracts X X X X X X X X Extracts X X X X
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