DCIT v. Kama Schachter Jewellery (P.) Ltd. (2021) 189 ITD 21 / 213 TTJ 537/ 205 DTR 180 (Mum.)(Trib.)

S. 271G : Penalty-Documents-International transaction-Transfer pricing-Manufacture of high end jewellery-Not maintained documents as required due to practical difficulties-Levy of penalty is held to be not valid. [S. 92D(3), Rule 10D(3)]

Dismissing the appeal of the revenue the Tribunal held that since there were practical difficulties involved in furnishing segmental details of AE transactions and non-AE transactions in diamond industry levy of penalty was held to be not valid. (AY. 2013-14)