section 271G
of the Act for violation of the provisions of section 92D(3) of the Act read ... under the rule 10D(1) and sub section
(3) of the sec 92D of the I.T. Act in respect of the
international transactions entered
have not been
kept and maintained by assessee as required under section 92D(1) and Rule
made in this behalf or information or date used ... required to furnished by a notice
issued under sub-section (3) of 92D. The Assessing Officer may proceed
failed to keep and maintain information and document the specified under
section 92D(1) of the Act on the ground that the transaction ... failed to keep
and maintain information and document as required in section 92D(1) of the
Act, whereas the notice under section 274 read with
holding that there was reasonable cause for
non-compliance of sec.92D r/w Rule 10D(1) without specifying the cause
of such noncompliance ... been called for by the TPO
within the meaning of section 92D(3) of the Income tax Act, 1961. The
details are relevant within
purposes of this section and sections 92 , 92C , 92D and 92E ,"international
transaction" means a transaction between two or more associated enterprises, either
purpose of this section and sections 92, 92C, 92D and
92E, "international transactions" means a transaction between two or
more associated enterprises, either
data in the transfer pricing stud y report maintained as
per section 92D of the Act read with Rule 10D of the Income-tax Rules
contemporaneous data in the transfer pricing study report
maintained as per Section 92D of the Income-tax Act, 1961 ('the Act')
read with
purposes of this section and
sections 92 , 92C , 92D and 92E , "international transaction" means a transaction
between two or more associated enterprises, either
purposes of this section and sections 92 , 92C , 92D and 92E ,
"international transaction" means a transaction between two or more associated
enterprises, either
