Penalty u/s 271(1)(c) - Transfer Pricing adjustment made -...

Penalty u/s 271(1)(c) - Transfer Pricing adjustment made - applying the analysis of the term ‘good faith’ and ‘due diligence’ we are of the considered view that in the present case the assessee has computed the ALP in respect of the international transaction in good faith and with due diligence. Accordingly, we find no infirmity in the impugned order passed by the learned CIT(A) directing deletion of penalty levied under section 271(1)(c) - AT