In the result, the appeal of the assessee is partly allowed
Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)
transfer pricing audit has certified that the particulars given in the Annexure of Form 3CEB are true and correct. 8.4 On the facts and the circumstances of the case, the Ld. PCIT has erred in holding that there was a deliberate attempt of the appellant of non-disclosure by not filing Balance sheet in VAT15BS and Profit & loss account