https://www.taxtmi.com/caselaws?id=793109 Penalty under section 271G was considered unsustainable where the foreign entity was found not to be an associated enterprise within section 92A. On that factual finding, the transaction did not constitute an international transaction, so the obligation to maintain transfer pricing documentation under section 92D(3) and Rule 10D did not arise. The absence of any transfer pricing adjustment by the TPO further supported that penalty was not exigible. The deletion of penalty was therefore upheld in favour of the assessee. en-us Wed, 20 May 2026 00:00:00 +0530 Tue, 09 Jun 2026 07:50:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793109 Penalty under section 271G was considered unsustainable where the foreign entity was found not to be an associated enterprise within section 92A. On that factual finding, the transaction did not constitute an international transaction, so the obligation to maintain transfer pricing documentation under section 92D(3) and Rule 10D did not arise. The absence of any transfer pricing adjustment by the TPO further supported that penalty was not exigible. The deletion of penalty was therefore upheld in favour of the assessee. Case-Laws Income Tax Wed, 20 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793109