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Penalty u/s 271G - requirement of maintenance of segment profitability between AEs and non-AEs transactions - non-maintenance of details in terms of section 92D(3) of IT Act r.w. Rule 10D of Income Tax Rules, 1962 - in the instant case there was reasonable cause for non-maintaining the details, which were required in terms of Rule 10D of the Rules - CIT(A) rightly deleted the penalty - AT