Held that Considering practical difficulties in furnishing segment-wise details of AE segment and non-AE segment transactions in the diamond industry, no penalty under section 271G could be imposed. Followed ACIT v. D. Navinchandra Exports (P.) Ltd. [2017] 87 taxmann.com 306 (Mum)(Trib). (AY. 2013-14)
DCIT v. Dharmanandan Diamonds (P) Ltd. (2022) 195 ITD 717 (Mum.)(Trib.)
S. 271G : Penalty-Documents-International transaction-Transfer pricing-Diamond industry-Practical difficulties in furnishing segment-wise details of AE segment and non-AE segment-Penalty not leviable. [S. 92D(3)]