https://www.taxtmi.com/caselaws?id=466758 Whether penalty for failure to maintain transfer pricing documents can be sustained where the AO did not identify which Rule 10D categories were missing: the Tribunal applied the principle that Revenue must particularise the specific documents or information not maintained before imposing penalty, and that a TPO's finding that the assessee furnished required details and that the international transaction was at arm's length negates asserted default. Because the AO's proceedings were non specific and the TPO recorded no default or recommendation for penalty, the penalty under Section 271AA was held unsustainable and deleted by CIT(A). en-us Tue, 25 Feb 2025 00:00:00 +0530 Wed, 18 Feb 2026 17:23:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466758 Whether penalty for failure to maintain transfer pricing documents can be sustained where the AO did not identify which Rule 10D categories were missing: the Tribunal applied the principle that Revenue must particularise the specific documents or information not maintained before imposing penalty, and that a TPO's finding that the assessee furnished required details and that the international transaction was at arm's length negates asserted default. Because the AO's proceedings were non specific and the TPO recorded no default or recommendation for penalty, the penalty under Section 271AA was held unsustainable and deleted by CIT(A). Case-Laws Income Tax Tue, 25 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466758