Substantial compliance in transfer pricing documentation defeats penalty for diamond trade record shortfall where arm's length pricing stood accepted

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....Penalty for failure to furnish transfer pricing documentation was deleted because the assessee had substantially complied by producing transfer pricing study reports, available segmental information and supporting documents, while the TPO accepted the benchmarking results and did not disturb the arm's length price. The alleged deficiency was only the absence of transaction-specific profitability in the form sought by the TPO, which was treated as a technical or venial breach. The Tribunal also accepted reasonable cause arising from the practical difficulty of precise AE and non-AE cost allocation in the diamond trade, and distinguished the contrary reliance on Shatrunjay Diamonds.....