No penalty under Expl. 7 to s. 271 (1) (c) for bona fide transfer pricing adjustments

RELEVANT EXTRACT Expl. 7 to s. 271 (1) (c) provides that in the case of an assessee who has entered into an international transaction, any amount added or disallowed in computing the total income u/s 92C (4) shall for purposes of s. 271 (1) (c) be deemed to represent income in respect of which particulars have been concealed or inaccurate particulars furnished unless the assessee shows that the s. 92C computation was made in good faith and with due diligence. The assessee, a call centre, adopted the Transactional Net Margin Method (“TNNM”) and showed an operating profit to operatin...