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 ... Tulsibhai
Dholakia
Pintu Tulsibhai Dholakia
Dholakia
Ankit Bharatbhai Patel
Notices under Sec. 92D(3) r.w Rule 10D were issued
assessee was directed to furnish the
documents specified under Sec. 92D and Sec. 92E of the 'Act'. The
TPO further examining the details ... upon the assessee to furnish the
requisite details in terms of Sec. 92D(3). However, the assessee once
again expressed its inability to furnish
failed to furnish documents or informations
as required under section 92D(3) of the Act. For this assessee
has raised the identically worded grounds ... keep and maintain any
information required by sub-section (1) of
section 92D of the Act r.w. Rule 10D of
the Income-tax Rules
notice U/s 92CA(1) r.w.s. 92D(3) of the IT. Act, 1961 "
3. "Whether on the facts ... particularly, Section 92 , 92C and section 92D of the I.T. Act
and Rule 10C, Rule 10B(1), Rule 10B(2) and (3) and Rule
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
assessee had not maintained the documents and
information as required u/s. 92D r.w.r. 10D of the I. T Rules, that value ... exceeding Rs.1 Crore, that as per rule 10D r.w.s.92D & 271AA,that assessee had
to maintain and keep prescribed information
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
should be counted from the date of receipt of notice u/s. 92D(3) and
not notice u/s. 92CA ... 18th August 2016
has submitted as under;
a) As per section 92D(3J of the I.T. Act 1961, the assessee is required to
furnish
assessee had failed to
furnish details and documents required u/s 92D(3) of the l T Act , and by deciding the case merely ... submission of details by the assessee as required u/s.92D(3) .
4. Whether on facts & circumstances of case
271G is for default in
complying with provisions to section 92D(3) and 92C whereas the
notice dated 17.02.2016 was issued to the assessee ... submission of
documents which is clearly required as per provisions of Section
92D(3).
2. On the facts and circumstances of the case
