No Section 270A(8) Penalty for TP Adjustment Without Proof of Deliberate Concealment: Madras HC

Verizon Data Services India Private Limited Vs DCIT (Madras High Court) Madras HC: No 270A(8) Penalty Without Proof of Deliberate Concealment; Holds Verizon’s TP Compliance Bars ‘Misreporting’ Tag Facts: The Petitioner, Verizon Data Services India Private Limited, filed its return of income for the Assessment Year 2020–21 on 24.12.2020 declaring a gross total income of Rs. 2,83,97,38,290/-. During the course of assessment proceedings, a reference was made under Section 92CA(1) of the Income Tax Act, 1961 to the Transfer Pricing Officer (TPO) for determination of the Arm’s Length Pr...