Penalty u/s 271G untenable as no transfer pricing adjustment possible due to omission of section 92BA(i): ITAT Mumbai

ITO Vs Aura Spinwell Limited (ITAT Mumbai)

Penalty u/s 271G untenable as no transfer pricing adjustment possible due to omission of section 92BA(i): ITAT Mumbai

ITAT Mumbai held that no transfer pricing adjustment could have been made in the hands of assessee on account of ALP of specified domestic transactions as section 92BA(i) of Income Tax Act was omitted. Thus, since provisions of section 92D are not applicable, penalty u/s. 271G of the Income Tax Act untenable.

Facts-

Assessee is a company engaged in the business of tradi

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