DCIT CENTRAL CIRCLE 1(1) , MUMBAI vs. CARBON CREATION EXPORTS PVT. LTD, MUMBAI

ITA 7818/MUM/2025Status: DisposedITAT Mumbai30 June 2026AY 2014-1512 pages
AI SummaryDismissed

What were the facts?

The assessee, engaged in the diamond trade, failed to provide segmental profitability for transactions with associated enterprises (AEs) and non-AEs as required by the TPO. The AO levied a penalty under Section 271G for this failure.

What did the Tribunal hold?

The Tribunal held that the assessee had a reasonable cause for not furnishing the segmental accounts due to the peculiar nature of the diamond trade. The assessee had substantially complied with the requirements and furnished all practically maintainable information.

What were the issues?

Whether failure to furnish segmental profitability for AE and non-AE transactions constitutes a reasonable cause for non-levy of penalty under Section 271G.

Which sections of the Income-tax Act were involved?

Section 271G,Section 273B

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, MUMBAI BENCHES,

Before: SHRI OM PRAKASH KANT & SHRI ANIKESH BANERJEE

PER SHRI ANIKESH BANERJEE, JUDICIAL MEMBER:

The instant appeal of the revenue filed against the order of the Ld. Commissioner of Income Tax-Appeals-55, Mumbai [for brevity “Ld. CIT(A)], order passed under Section 250 of the Income Tax Act, 1961 for Assessment Year 2014-15, date of order 02.09.2025. The impugned order emanated from the order of the Ld. Deputy Commissioner of Income Tax (Transfer Pricing)- 1(3)(1), Mumbai (for brevit

The order continues below.

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