No Penalty Imposed: Transfer Pricing Adjustments Deemed Debatable, All Related Disallowances and Additions Deleted u/s 271(1)(c.

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....Penalty u/s 271(1)(c) - addition on account of Transfer Pricing adjustment relating to payment of commission - it is evident that these are debatable issues - In any case of the matter, while deciding the quantum appeals of the assessee and the revenue in the earlier part of the order, we have deleted all the disallowances/additions based on which penalty under section 271(1)(c) of the Act was imposed.- No penalty - AT....