Tribunal held that reason for making said adjustments was denial of capacity utilization claimed by assessee, the same could not tantamount to filing of return without good faith and due diligence so as to levy penalty under section 271(1)(c) upon assessee. On appeal High Court affirmed the order of the Tribunal. (AY. 2007-08)
PCIT v. Giesecks & Devrient (India) (P.) Ltd. (2022) 285 Taxman 408 / 210 CTR 197 / 325 CTR 117 (Delhi)(HC)
S. 271(1)(c) : Penalty-Concealment-Transfer pricing-Adjustment for software development services-Deletion of penalty is held to be justified. [S. 92C]