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    <title>2019 (4) TMI 2196 - ITAT MUMBAI</title>
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    <description>Penalty under section 271G was discussed in the context of transfer pricing documentation under rule 10D, where the assessee had furnished the material relevant to the benchmarking method adopted and the arm&#039;s length price was accepted without adjustment. The remaining segment-wise or alternative-method details were treated as practically difficult to maintain in the diamond trade because goods lose distinct identity during processing and trading. The analysis emphasised substantial compliance and reasonable cause under section 273B, and noted that penalty should not survive where the required information is not specifically identified or the relevant material already available with the assessee has been furnished. On that basis, deletion of penalty was upheld.</description>
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    <pubDate>Wed, 10 Apr 2019 00:00:00 +0530</pubDate>
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      <title>2019 (4) TMI 2196 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=469887</link>
      <description>Penalty under section 271G was discussed in the context of transfer pricing documentation under rule 10D, where the assessee had furnished the material relevant to the benchmarking method adopted and the arm&#039;s length price was accepted without adjustment. The remaining segment-wise or alternative-method details were treated as practically difficult to maintain in the diamond trade because goods lose distinct identity during processing and trading. The analysis emphasised substantial compliance and reasonable cause under section 273B, and noted that penalty should not survive where the required information is not specifically identified or the relevant material already available with the assessee has been furnished. On that basis, deletion of penalty was upheld.</description>
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      <pubDate>Wed, 10 Apr 2019 00:00:00 +0530</pubDate>
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