ACIT v. DA Jhaveri (2022) 94 ITR 35 (SN) (Mum.)(Trib.)

S. 271G : Penalty-Documents-International transaction-Transfer pricing-Transactional Net Margin Method-Bifurcation of profits-Failure to furnish the details-Deletion of penalty is held to be valid. [S. 273B, R. 10D(1)]

Held that on the identical facts and circumstances for the AY. 2011-12, the benchmarking of the assessee having been accepted on identical facts, the assessee had a belief that such information was not required as well as not available, therefore, the assessee had reasonable cause under section 273B of the Act for not maintaining the information.. Deletion of penalty is held to be valid. (AY. 2011-12)