been initiated for failure to furnish information or
documents under section 92D of Income-tax Act, 1961?".
2) The Appellant prays that the order ... assessee has not furnished the information
or documentation as required under section 92D(3) of the Act in respect of
the international transaction not reported
requisite information and documents as sought by the
Ld. TPO under Section 92D of the Act read with Rule 10D(1) and Rule ... Rules, 1962 ('Rules') within the time limit
prescribed under Section 92D(3) of the Act;
2.2 That
under:
"Penalty for failure to furnish information or document under section 92D .
271G. If any person who has entered into an international transaction ... such information or
document as required by sub-section (3) of section 92D , the Assessing
Officer or the Transfer Pricing Officer as referred
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 ... information/ documents
were called for by TPO by issuing notice u/s 92D(3) . During the year
under consideration, the assessee entered into various international
issued dated 29.03.2016 ,
16.06.2016 and u/s. 92CA(2) r.w.s 92D(3) of the Act dated 25.07.2016 and
02.08.2016 requiring the assessee ... violation of rule 10D(1)
r.w.s 92D and rule 10D(3) of the I.T. rules. The Ld. CIT(A) on the other
will apply only to Sections 92 , 92B , 92C , 92D and 92E of the Act. He submitted,
concept of AE in Section 92A does not apply
pricing study report ('TP Study Report')
maintained as per Section 92D of the Income Act 1962 (the 'Act') read with Rule ... Transfer pricing study report (TP Study Report)
maintained as per section 92D of the Act read with Rule 100 of the Rules
92CA(2) of the Act, for furnishing
documents maintained as per Section 92D r.w.r. 10D. Notice u/s. 92D ... information or documents referred to in sub-section
(3) of section 92D and after considering such evidence as the Transfer
Pricing Officer may require
holding that there was reasonable cause for
non-compliance of sec. 92D read with Rule 10D(1) without specifying the
cause of such non-compliance ... furnish information or documents as required under sub-
section (3) of Section 92D . Reliance has been placed on CIT vs
Shatrunjay Diamonds (supra), in which
Dcit(Cc)-8(3), Mumbai vs Jsw Energy Limited, Mumbai on 19 December, 2025
IN
