https://www.taxtmi.com/caselaws?id=462494 The Tribunal dismissed Revenue's appeal and deleted penalty under section 271(1)(c) for transfer pricing adjustments. The Assessing Officer failed to invoke mandatory Explanation 7 to section 271(1)(c) when levying penalty for international transaction adjustments under section 92C. Additionally, the penalty order suffered from incurable ambiguity by not specifying whether penalty was for concealment of income or furnishing inaccurate particulars. The Tribunal held that Explanation 7 is mandatory in transfer pricing penalty cases and penalty orders must clearly specify charges to ensure procedural fairness and statutory compliance. en-us Fri, 07 Sep 2018 00:00:00 +0530 Thu, 26 Jun 2025 08:35:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=462494 The Tribunal dismissed Revenue's appeal and deleted penalty under section 271(1)(c) for transfer pricing adjustments. The Assessing Officer failed to invoke mandatory Explanation 7 to section 271(1)(c) when levying penalty for international transaction adjustments under section 92C. Additionally, the penalty order suffered from incurable ambiguity by not specifying whether penalty was for concealment of income or furnishing inaccurate particulars. The Tribunal held that Explanation 7 is mandatory in transfer pricing penalty cases and penalty orders must clearly specify charges to ensure procedural fairness and statutory compliance. Case-Laws Income Tax Fri, 07 Sep 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=462494