https://www.taxtmi.com/caselaws?id=462495 Penalty under Section 271(1)(c) in a transfer pricing adjustment was deleted because the Tribunal treated the underlying Arm's Length Price dispute under Section 92C, read with the transfer pricing report and Rule 10B, as debatable. The Tribunal's view was considered reasonable, especially since the original addition had been reduced by the first appellate authority and that view was affirmed. The High Court held that no substantial question of law arose, so Explanation 7 did not warrant interference. The deletion of penalty was upheld and the Revenue's challenge failed. en-us Mon, 19 Mar 2018 00:00:00 +0530 Thu, 26 Jun 2025 08:36:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=462495 Penalty under Section 271(1)(c) in a transfer pricing adjustment was deleted because the Tribunal treated the underlying Arm's Length Price dispute under Section 92C, read with the transfer pricing report and Rule 10B, as debatable. The Tribunal's view was considered reasonable, especially since the original addition had been reduced by the first appellate authority and that view was affirmed. The High Court held that no substantial question of law arose, so Explanation 7 did not warrant interference. The deletion of penalty was upheld and the Revenue's challenge failed. Case-Laws Income Tax Mon, 19 Mar 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=462495