https://www.taxtmi.com/caselaws?id=797480 Penalty for failure to furnish transfer-pricing documentation under Section 271G requires identified information or documents to be specifically requisitioned under Section 92D(3). An ambiguous penalty notice that does not identify the allegedly missing material cannot establish this prerequisite. Notices issued under Section 92CA(2) do not substitute for a statutory requisition under Section 92D(3) or prove non-production within the prescribed period. Where the taxpayer furnishes the transfer-pricing study report in response to a specific Section 92D(3) notice within time, penalty is not sustainable. Because Section 271G is penal in nature, its procedural requirements require strict compliance. en-us Wed, 19 Aug 2026 00:00:00 +0530 Sat, 22 Aug 2026 10:33:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797480 Penalty for failure to furnish transfer-pricing documentation under Section 271G requires identified information or documents to be specifically requisitioned under Section 92D(3). An ambiguous penalty notice that does not identify the allegedly missing material cannot establish this prerequisite. Notices issued under Section 92CA(2) do not substitute for a statutory requisition under Section 92D(3) or prove non-production within the prescribed period. Where the taxpayer furnishes the transfer-pricing study report in response to a specific Section 92D(3) notice within time, penalty is not sustainable. Because Section 271G is penal in nature, its procedural requirements require strict compliance. Case-Laws Income Tax Wed, 19 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797480