No penalty for non-furnishing of segmental details of AE & non-AE transactions due to practical difficulties

DCIT Vs Ratnakala Export Pvt Ltd (ITAT Mumbai)

The only substantial issue that has to be decided is whether the CIT(A) was justified in deleting the penalty levied under section 271G, the other grounds being ancillary to this. From the facts of the case, it is evident that the Assessee has furnished the necessary details for determination of the arm’s length price though (ALP) was unable to provide segment-wise profit & loss account of the AE segment and the non AE segment since the Assessee did not maintain separate b

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