Penalty u/s. 271(1)(c) unsustainable as no adjustment on transfer pricing issue wouldn’t subsist

Trip Advisor Travel India Pvt Ltd Vs ACIT (ITAT Delhi) ITAT Delhi held that as no adjustment on transfer pricing issue would subsist and therefore there is no question of penalty u/s. 271(1)(c) of the Income Tax Act on such addition. Facts- The assessee is a company stated to be engaged in providing marketing and other services to Trip Advisor Ltd., The assessee electronically filed its return of income for A.Y 2011-12 on 29.11.2011 declaring total of income at Rs. 62,04,833/-. A.O. has noted that during the year under consideration, assessee had entered into international transactions with it...