No penalty for bonafide different perspective in ALP calculation

ITO Vs Tianjin Tianshi India Pvt (ITAT Delhi) The issue under consideration is that whether the penalty will be levied only because there is different perspective in calculation of ALP by the assessee and the by the department even though the intention of the assessee is bonafide? The assessee is one of the group companies of China based TIENS Group of Companies. The business of the assessee, is Trading/Distribution of Food Supplements and Health Care Equipments. The products dealt with by the Company are basically products manufactured at China or other places by Group concerns. Another Group...