https://www.taxtmi.com/caselaws?id=309123 In the case concerning Assessment Year 2007-08, the Tribunal dismissed the Revenue's appeal against the deletion of the penalty imposed under section 271(1)(c) for adjustments made to international transactions. The Tribunal found that the Transfer Pricing Officer's jurisdiction was invalid, leading to the deletion of the adjustment and rendering the penalty unsustainable. Similarly, in the case for Assessment Year 2008-09, the Tribunal upheld the deletion of the penalty by the CIT(A) due to the AO's failure to specify the limb of section 271(1)(c) at the initiation stage, deeming the penalty order legally flawed and unsustainable. The Tribunal emphasized the importance of proper satisfaction in penalty proceedings at all stages. en-us Thu, 15 Nov 2018 00:00:00 +0530 Fri, 11 Aug 2023 13:49:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=309123 In the case concerning Assessment Year 2007-08, the Tribunal dismissed the Revenue's appeal against the deletion of the penalty imposed under section 271(1)(c) for adjustments made to international transactions. The Tribunal found that the Transfer Pricing Officer's jurisdiction was invalid, leading to the deletion of the adjustment and rendering the penalty unsustainable. Similarly, in the case for Assessment Year 2008-09, the Tribunal upheld the deletion of the penalty by the CIT(A) due to the AO's failure to specify the limb of section 271(1)(c) at the initiation stage, deeming the penalty order legally flawed and unsustainable. The Tribunal emphasized the importance of proper satisfaction in penalty proceedings at all stages. Case-Laws Income Tax Thu, 15 Nov 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=309123