Penalty for transfer pricing adjustment not justified if ALP was determined in good faith and with due diligence

M/s Halcrow Consulting India Pvt. Ltd. Vs. DCIT (ITAT Delhi) In this case Grounds on which the ALP determined by the assessee has been rejected are reasonably debatable. The assessee had obtained a transfer pricing study from an outside expert and the objectivity of the same was not called into question. Therefore, lack of due diligence in determining the ALP is neither indicated nor can be inferred. In such a situation, it cannot be said that the assessee had not determined the ALP in accordance with the scheme of section 92C in good faith and with due diligence and accordingly, the conditio...