read with Rule 10E requires assesses to report
international transactions in Form 3CEB. Section 92F defines various
terms, the relevant portion thereof reads as under ... section (2B) applies only where an
assessee does not file Form 3CEB to wit in cases where the assessee
does not disclose any international transaction
transaction which the assessee had with the associated
enterprises (AE) in Form 3CEB as is required in terms of Rule ... These details in Form 3CEB along with the
report of an accountant are at pages 162 to 168 of the assessee's paper book
rate of 7.19% per
annum. The writ applicant filed Form 3CEB, wherein there is a
requirement in clause 14 to make a disclosure about ... writ applicant that it
had appropriately disclosed the transaction in the Form 3CEB.
6 The respondent No.1 issued a show cause notice dated
fact that the
Appellant has filed the accountants report in Form 3CEB under
section 92E of the Act out of abundant caution in respect ... assessee,
as assessee itself has filed the audit report in form 3CEB and
further has also undertaken benchmarking process and having
regard to the details
Further, the assessee had not filed Form
3CEB with the Return of Income, as required u/s 92E of the Act.
Accordingly the case ... account of deemed rent. Since the
assessee had not filed Form 3CEB with Return of Income, as
required u/s 92E of the Act, penalty
obligation on it to report the said transaction
in Form 3CEB. This position is also confirmed by the said Form
prescribed for assessment year ... Enterprises (AE). The said transaction was not reported by assessee in
Form-3CEB. The Assessing Officer while making the scrutiny
assessment issued show-cause notice
assessee's failure
to file the Audit Report in Form 3CEB, the AO simultaneously initiated
penalty proceedings by issue of notice under section ... supra), by not filing the Audit Report in Form 3CEB, the assessee has
failed to comply with the requirement of the provisions of section
rate of 7.19% per
annum. The writ applicant filed Form 3CEB, wherein there is a
requirement in clause 14 to make a disclosure about ... writ applicant that it
had appropriately disclosed the transaction in the Form 3CEB.
6 The respondent No.1 issued a show cause notice dated
whether “value of international transactions is correctly
shown in Form 3CEB and the return of income”. Subsequently, the TPO
issued notice dated 19.12.2018, stating that ... whether the value of international transactions is correctly
shown in Form 3CEB and return of income, whereas the notice issued by
the TPO states that
issue of shares was reported in the Form 3CEB issued
by a Chartered Accountant certifying that the shares were
issued at arms' length price ... Section 92CA(1) of
the Act, the assessee furnished report in Form 3CEB from a
Chartered Accountant certifying that the price of the equipment
purchased
