2024 (5) TMI 1496

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....ue : Shri P.D. Chougule. ORDER PER AMIT SHUKLA (J.M): The aforesaid appeal has been filed by the assessee against order dated 12/07/2023 passed by NFAC against penalty order u/s. 271G for the A.Y. 2015-16. 2. The assessee is aggrieved by levy of penalty of Rs. 40,47,075/- u/s. 271G being 2% earned on total value of Specified Domestic Transaction of Rs. 20,23,52,771/-. 3. T....

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....re it has been mentioned that during the course of transfer pricing proceedings assessee had not furnished any such details which were required. In fact in the order u/s. 92CA(3) dated 24/10/2018, the ld. TPO had noted that assessee had furnished all the details required and value of Specified Domestic Transaction with the AE in regard to ALP is not being disturbed. For the sake of ready reference....

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....ces u/s 92CA(2) and 92D(3) of Act dated 16.08.2017 were issued requesting the assessee to file all the evidence and documents relied in support of the computation of arm's length price in relation to the specified domestic transactions entered into with its AEs. In response to said notices, The assessee furnished certain submissions in tapal. 3. Considering the facts and circumstances....