assessee was required to file the T.P. study maintained u/s
92D(3) r.w.r 10D of the Act. The AO observed that ... Hyderabad
the transaction exceeded the time limit prescribed u/s 92D(3) of
the Act. Therefore, penalty proceedings u/s 271G were initiated
assessee
was required to file the TP study maintained u/s 92D(3) r/w rule 10D.
Accordingly, a request was made ... determination of ALP.
c) No notice was issued as required u/s 92D(3).
7
ITA Nos. 737, 738, 739 & 740/H/16
Karvy
keep and furnishing of the
information and documents as required u/s 92D of the Act. The
Assessing Officer finally levied the penalty ... assessee to
maintain the record, documents and information as required u/s
92D of the I.T. Act, 1961. He has supported the order
segment in its documentation
maintained under section 92D , but learned TPO computed margins of
assessee at entity level and not considered segment margin analysis given ... against the type of transaction as per the
documentation maintained under section 92D of the Income-tax Act,
1961. The reason for adopting each
that the assessee failed to
furnish information/documentation as required under Section 92D
of the Act read with Rule 10D and without demonstrating any
wilful ... that the assessee had furnished all relevant documentation
as required under section 92D of the Act r.w. Rule 10D of the Income
Tax Rules
observed that
assessee has not complied with the provisions of Section 92D of
the Act r.w. Rule 10D of the IT Rules ... information or documents as required by sub- Section 3 of Section
92D of the Act. Therefore, he proposed to initiate the penalty
proceedings
Rain Cii Carbon (India) Limited, ... vs Dcit, Circle 3(1), Hyderabad on 26 April, 2017
purpose of this section and sections
92, 92C, 92D and 92E, "international transaction" means a
transaction between two or more associated enterprises, either
Assessee maintained the relevant Transfer Pricing [TP]
documentation as required u/s 92D of the Income Tax Act [Act]
r/w Rule
also maintained the relevant transfer pricing
(TP) documentation as required u/s 92D of the Act r/w Rule 10D of
the Income-tax Rules
