https://www.taxtmi.com/caselaws?id=764998 ITAT Ahmedabad ruled in favor of the assessee regarding penalty under section 271AA for failure to maintain transfer pricing documents. The tribunal held that revenue must specify which documents were not maintained before imposing penalty, following Delhi HC precedent in CIT vs Leroy Somer Controls India. The penalty order was deemed procedurally flawed as it was passed without proper show-cause notice or adequate hearing opportunity. Additionally, since the international transactions were already held at arm's length by the TPO, the penalty was unsustainable in law. en-us Tue, 21 Jan 2025 00:00:00 +0530 Wed, 22 Jan 2025 14:25:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=764998 ITAT Ahmedabad ruled in favor of the assessee regarding penalty under section 271AA for failure to maintain transfer pricing documents. The tribunal held that revenue must specify which documents were not maintained before imposing penalty, following Delhi HC precedent in CIT vs Leroy Somer Controls India. The penalty order was deemed procedurally flawed as it was passed without proper show-cause notice or adequate hearing opportunity. Additionally, since the international transactions were already held at arm's length by the TPO, the penalty was unsustainable in law. Case-Laws Income Tax Tue, 21 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=764998