No Penalty for bonafide difference of opinion in selection of transfer pricing method

Court: The Mumbai Income Tax Appellate Tribunal Citation: ACIT Vs. Firmenich Aromatics (India) Pvt. Ltd. [ITA No. 4654/Mum/2009] dated 17 May, 2010 Background The Mumbai Income Tax Appellate Tribunal (“the Tribunal”) has discussed the principles in relation to application of penalty provisions, under section 271(1)(c) of the Income-tax Act, 1961 (“the Act”), in case of a transfer pricing adjustment involving ACIT v. Firmenich Aromatics (India) Pvt. Ltd. [ITA No. 4654/Mum/2009] dated 17 May, 2010 Specifically, the Tribunal held that where there is a difference between th...