https://www.taxtmi.com/caselaws?id=752165 The ITAT Delhi ruled in favor of the assessee regarding penalty under section 271(1)(c) for transfer pricing adjustments. The Tribunal held that the AO failed to specify which limb of section 271(1)(c) applied when initiating penalty proceedings, making the penalty unsustainable. Additionally, since the transfer pricing addition was subject to appeal with substantial questions of law framed by the Delhi HC, the matter became debatable. Following the precedent in Chegg India case, the Tribunal concluded that no penalty could be levied on debatable issues and allowed the assessee's appeal, deleting the penalty. en-us Wed, 01 May 2024 00:00:00 +0530 Fri, 03 May 2024 07:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=752165 The ITAT Delhi ruled in favor of the assessee regarding penalty under section 271(1)(c) for transfer pricing adjustments. The Tribunal held that the AO failed to specify which limb of section 271(1)(c) applied when initiating penalty proceedings, making the penalty unsustainable. Additionally, since the transfer pricing addition was subject to appeal with substantial questions of law framed by the Delhi HC, the matter became debatable. Following the precedent in Chegg India case, the Tribunal concluded that no penalty could be levied on debatable issues and allowed the assessee's appeal, deleting the penalty. Case-Laws Income Tax Wed, 01 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=752165