3 results for “penalty u/s 271”+ Section 92D(3)clear
Sorted by relevance
In the result, these three appeals filed by the Revenue are dismissed
Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.176 To 178/Srt/2022 Assessment Years: (2012-13 To 2014-15) (Physical Hearing) The Acit, Central Circle-3, Vs. Antrix Diamond Exports Pvt. Ltd., Surat. 1006, Free Press Mark, Raheja Centre Nariman Point, Mumbai – 400021. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaca3403G (Revenue)/(Appellant) (Assessee)/(Respondent) Assessee By Ms Ekta Sanghvi, Ca Revenue By Shri Ashok B. Koli, Cit(Dr) Date Of Hearing 10/02/2023 21/03/2023 Date Of Pronouncement
92D and under Rule 10D(3). Therefore penalty of Rs.5,23,62,122/- was levied at 2% of value of the international transaction. 4.1 Before me, it is contended that the detailed analysis undertaken by the assessee to justify the transaction with AE under TNMM method at entity level was submitted from time to time along with all the required