https://www.taxtmi.com/caselaws?id=469643 Penalty under section 271G may be deleted where the assessee shows reasonable cause for not maintaining or furnishing transfer pricing documentation and segmental results, particularly when business operations make separate records impracticable. The Tribunal accepted the assessee's explanation that diamonds of varying size, quality, colour and weight from AEs and non-AEs were mixed in the manufacturing and export process, and treated the facts as identical to the earlier year where section 273B relief had been accepted. It also held that Shatrunjay Diamonds, decided in the context of section 40A(2)(b) and a different burden-of-proof issue, did not govern section 271G penalty. en-us Tue, 17 Dec 2024 00:00:00 +0530 Thu, 25 Jun 2026 18:57:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469643 Penalty under section 271G may be deleted where the assessee shows reasonable cause for not maintaining or furnishing transfer pricing documentation and segmental results, particularly when business operations make separate records impracticable. The Tribunal accepted the assessee's explanation that diamonds of varying size, quality, colour and weight from AEs and non-AEs were mixed in the manufacturing and export process, and treated the facts as identical to the earlier year where section 273B relief had been accepted. It also held that Shatrunjay Diamonds, decided in the context of section 40A(2)(b) and a different burden-of-proof issue, did not govern section 271G penalty. Case-Laws Income Tax Tue, 17 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469643