https://www.taxtmi.com/caselaws?id=756254 ITAT Delhi dismissed Revenue's appeal challenging deletion of penalty u/s 271(1)(c) imposed on transfer pricing adjustment u/s 92CA. The court held that AO failed to examine whether penalty was imposable on such adjustments, merely relying on TPO's addition. Under Explanation 7 to section 271(1)(c), assessee only needs to demonstrate ALP computation in accordance with section 92C in good faith with due diligence. Since there was no dispute over methodology and no allegation of lack of good faith or due diligence by assessee, penalty conditions were not satisfied. en-us Thu, 30 May 2024 00:00:00 +0530 Wed, 31 Jul 2024 08:36:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=756254 ITAT Delhi dismissed Revenue's appeal challenging deletion of penalty u/s 271(1)(c) imposed on transfer pricing adjustment u/s 92CA. The court held that AO failed to examine whether penalty was imposable on such adjustments, merely relying on TPO's addition. Under Explanation 7 to section 271(1)(c), assessee only needs to demonstrate ALP computation in accordance with section 92C in good faith with due diligence. Since there was no dispute over methodology and no allegation of lack of good faith or due diligence by assessee, penalty conditions were not satisfied. Case-Laws Income Tax Thu, 30 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=756254