SEQUENCE DESIGN (INDIA) PRIVATE LIMITED,PUNE MAHARASHTRA vs. JOINT COMMISSIONER OF INCOME TAX CIRCLE 1(1) PUNE, PUNE
In the result, appeal of the assessee is allowed
ITA 2106/PUN/2024[2015-2016]Status: DisposedITAT Pune16 May 2025AY 2015-2016
Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2106/Pun/2024 Assessment Year : 2015-16
For Appellant: Shri Nikhil PathakFor Respondent: Shri Manish Mehta
Section 143(1)(a)Section 143(3)Section 250Section 271ASection 273BSection 92D(1)
Transfer Pricing adjustment already offered to tax in the A.Y.
2009-10 to A.Y. 2014-15, it was excluded while computing the total income for A.Y. 2014-15. On the strength of these facts, it was stated that assessee had reasonable cause not to report the said transaction in Form No.3CEB and therefore no penalty is leviable u/s.271AA
