No Penalty for Assessee: Section 271G Non-Compliance Didn't Affect Arm's Length Price Determination by Transfer Pricing Officer.

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....Penalty u/s 271G - non–maintenance of documents which the assessee is required to maintain under the statutory provisions, the Transfer Pricing Officer found it difficult to determine, the arm’s length price of the transactions with the AE - The blame for failure on the part of the TPO to determine the arm’s length price cannot be fastened with the assessee - No penalty - AT....