https://www.taxtmi.com/caselaws?id=796304 Failure to furnish separate segmental profitability for associated-enterprise and non-associated-enterprise transactions did not attract penalty where preparing the details was impracticable in the diamond trade due to mixed lots and varying diamond characteristics. The assessee provided Form 3CEB, audit reports and other transfer-pricing documentation, and no arm's length price adjustment was made. These facts established substantial compliance with transfer-pricing documentation requirements and reasonable cause for incomplete segmental information. Penalty under Section 271G was therefore not leviable, and its deletion was sustained. en-us Tue, 30 Jun 2026 00:00:00 +0530 Tue, 04 Aug 2026 08:39:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796304 Failure to furnish separate segmental profitability for associated-enterprise and non-associated-enterprise transactions did not attract penalty where preparing the details was impracticable in the diamond trade due to mixed lots and varying diamond characteristics. The assessee provided Form 3CEB, audit reports and other transfer-pricing documentation, and no arm's length price adjustment was made. These facts established substantial compliance with transfer-pricing documentation requirements and reasonable cause for incomplete segmental information. Penalty under Section 271G was therefore not leviable, and its deletion was sustained. Case-Laws Income Tax Tue, 30 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796304