Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
The ITAT held that the penalty proceedings under section 271C were time-barred as the penalty order was passed beyond the six-month limitation period prescribed under section 275(1)(c) from the date the AO referred the matter to the Addl. CIT. Since the reference was made on 10.10.2016, the penalty order issued thereafter exceeded the statutory limitation period. Consequently, the penalty order was quashed as being invalid and barred by limitation. The appeals filed by the assessee were allowed accordingly.
The ITAT held that the penalty proceedings under section 271C were time-barred as the penalty order was passed beyond the six-month limitation period prescribed under section 275(1)(c) from the date the AO referred the matter to the Addl. CIT. Since the reference was made on 10.10.2016, the penalty order issued thereafter exceeded the statutory limitation period. Consequently, the penalty order was quashed as being invalid and barred by limitation. The appeals filed by the assessee were allowed accordingly.
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