In the result, the appeal of the assessee is allowed
Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member)
Transfer Pricing Officer, where the assessee had maintained information and documents as prescribed under section 92D, declared the international transaction under Chapter X, and, disclosed all the material facts relating to the transaction; and (e) the amount of undisclosed income referred to in section 271AAB. 2.3 Further reliance was placed on the Coordinate Bench decision in case of VDB Infra