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Penalty u/s 271(1)(c) for furnishing inaccurate particulars of income - adjustment made u/s 92CA - penalty levied u/s 271(1)(c) on the adjustment made u/s 92CA is not legally valid. CIT(A) rightly deleted addition as AO relied on adjustment made by TPO without examining whether penalty was imposable. Explanation 7 to Section 271(1)(c) places onus on assessee to show ALP computed u/s 92C in good faith and due diligence. Assessee computed ALP per Section 92C, no dispute over MAM, PLI or timescale. AO/TPO adopted different comparables. AO did not allege lack of good faith and due diligence. AO failed to demonstrate specific act, fact or conduct proving lack of good faith and due diligence. Lack of due diligence in ALP determination not indicated or inferable. Conditions for invoking Explanation 7 to Section 271(1)(c) did not exist. Revenue's appeal dismissed.
Penalty u/s 271(1)(c) for furnishing inaccurate particulars of income - adjustment made u/s 92CA - penalty levied u/s 271(1)(c) on the adjustment made u/s 92CA is not legally valid. CIT(A) rightly deleted addition as AO relied on adjustment made by TPO without examining whether penalty was imposable. Explanation 7 to Section 271(1)(c) places onus on assessee to show ALP computed u/s 92C in good faith and due diligence. Assessee computed ALP per Section 92C, no dispute over MAM, PLI or timescale. AO/TPO adopted different comparables. AO did not allege lack of good faith and due diligence. AO failed to demonstrate specific act, fact or conduct proving lack of good faith and due diligence. Lack of due diligence in ALP determination not indicated or inferable. Conditions for invoking Explanation 7 to Section 271(1)(c) did not exist. Revenue's appeal dismissed.
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