No Penalty for TP Addition if ALP Calculated in Good Faith u/s 271(1)(c); Mere ALP Differences Exempt.

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....Penalty u/s 271(1)(c) - TP addition - if the assessee computed the ALP of the international transaction as per the manner prescribed in good faith and due diligence then simply because now there remains some difference in the manner of determination of the ALP, it cannot be held that the assessee either concealed the particulars of its income or furnished inaccurate particulars of income - no penalty....