2024 (6) TMI 795

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.... RAHMAN ( AM ) 1. This appeal is filed by the revenue against order of Learned Commissioner of Income-Tax (Appeals)-56, Mumbai [hereinafter in short "Ld.CIT(A)"] dated 24.06.2016 for the A.Y.2011-12. 2. Brief facts of the case are, assessee has entered into international transactions as under and benchmarked the transaction by adopting TNMM Method: - S. No. Description Amount in Rs. Bench....

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....ns. The above said data was submitted before Transfer Pricing Officer. The Transfer Pricing Officer has not discussed anything in his report and considering the difficulties in the diamond industry and complication involved in polished and non-polished diamonds, the Transfer Pricing Officer has accepted the ALP and not proposed any adjustment. However, proceeded to levy penalty under section 271G ....

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....ions. However, on the query raised by the Transfer Pricing Officer assessee has made an attempt to segregate the figures of sales and purchases segment-wise and submitted the same before Transfer Pricing Officer. The Transfer Pricing Officer has considered the same or atleast not discussed anything in his order. However, proceeded to levy the penalty under section 271G of the Act and at the same t....