ITO v. Aura Spinwell Ltd. (2024)114 ITR 29 (SN)(Mum)(Trib)

S. 271G : Penalty-Documents-International transaction-Transfer pricing-Arm’s Length Price-Domestic transactions-Reference to Transfer Pricing Officer-Clause (I) Of Section 92BA(i)) is omitted By Finance Act, 2017, with effect from 1-4-2017-Penalty is deleted. [S.92BA, 92CA]

Held, that the transfer pricing adjustment was made with respect to the specified domestic transactions covered under section 92BA(i), which clause was omitted by the Finance Act, 2017, with effect from April 1, 2017. Since there was no applicability of transfer pricing provisions to the specified domestic transactions of the assessee covered under section 92BA(i), there could not be any requirement of maintenance of the document.  The assessee cannot  not be penalised for not mainttainng the documents. (AY.2016-17)C

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