https://www.taxtmi.com/highlights?id=104318 Penalty under Explanation 7 to section 271(1)(c) was not sustainable on a transfer pricing adjustment where the taxpayer used the prescribed TNMM method, disclosed its filters, comparables and operating-margin computation, and acted in good faith with due diligence. Differences over the profit level indicator and treatment of operating items were debatable interpretational issues, not evidence that the arm's length price had been computed outside the statutory framework. Mere differences of opinion on such issues do not attract penalty. The High Court sustained deletion of the penalty and dismissed the Revenue's appeal for want of a substantial question of law. en-us Tue, 29 Sep 2026 08:34:54 +0530 Tue, 29 Sep 2026 08:34:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=104318 Penalty under Explanation 7 to section 271(1)(c) was not sustainable on a transfer pricing adjustment where the taxpayer used the prescribed TNMM method, disclosed its filters, comparables and operating-margin computation, and acted in good faith with due diligence. Differences over the profit level indicator and treatment of operating items were debatable interpretational issues, not evidence that the arm's length price had been computed outside the statutory framework. Mere differences of opinion on such issues do not attract penalty. The High Court sustained deletion of the penalty and dismissed the Revenue's appeal for want of a substantial question of law. Highlights Income Tax Tue, 29 Sep 2026 08:34:54 +0530 https://www.taxtmi.com/highlights?id=104318