The Tribunal held that the assessee had computed the arm’s length price in respect of the international transactions in good faith and with due diligence. There was no infirmity in the order passed by the Commissioner (Appeals) directing deletion of penalty levied under section 271(1)(c) of the Act.(AY. 2009-10).
Dy. CIT v. Sitel India Ltd. (2022)97 ITR 65 (SN)(Mum) (Trib)
S. 271(1)(c) : Penalty-Concealment-Transfer pricing-Conducted detailed functions, assets and risk analysis of international transactions-Documentations not rejected-Penalty not warranted. [S. 92C, 92D R.10D]