DCIT v. Convergys Customer Management Group Inc. (2023) 198 ITD 100 (Delhi) (Trib.)

S. 271AA : Penalty-Failure to keep and maintain books of accounts-Documents-International transaction-Transfer pricing-Not specified the documents / information which are required to be kept or maintained-Order of CIT(A) deleting the penalty is affirmed.[S.92D(1), 92D(2)]

Held that there was no dispute that assessee had maintained requisite documentation in respect of its reported international transaction of FTS and FIS and had also furnished details of various documentations maintained by it.  Assessing Officer had not specified documents/information which, in his view, were required to be kept and maintained under section 92D(1) and 92D(2) but were not kept and maintained by assessee. Order of CIT (A) deleting the penalty is affirmed.(AY. 2009-10)