https://www.taxtmi.com/caselaws?id=428613 Penalty under section 271AA was held unsustainable where the assessee had maintained and produced transfer pricing documentation, including functional and economic analysis, and the TPO drew no adverse inference from it. The assessment order did not identify any specific information or document required under section 92D read with Rule 10D that was missing. Prior Revenue rulings were treated as factually distinguishable because the present year did not rest on the same disallowance basis. The deletion of penalty was upheld because the Revenue failed to establish a concrete statutory default. en-us Mon, 03 Oct 2022 00:00:00 +0530 Tue, 04 Oct 2022 17:59:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=428613 Penalty under section 271AA was held unsustainable where the assessee had maintained and produced transfer pricing documentation, including functional and economic analysis, and the TPO drew no adverse inference from it. The assessment order did not identify any specific information or document required under section 92D read with Rule 10D that was missing. Prior Revenue rulings were treated as factually distinguishable because the present year did not rest on the same disallowance basis. The deletion of penalty was upheld because the Revenue failed to establish a concrete statutory default. Case-Laws Income Tax Mon, 03 Oct 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=428613