Section 271GH penalty not leviable if Assessee complies Rule 10D(i)

Procter & Gamble Home Products Private Limited Vs DCIT (ITAT Mumbai)

Main allegation of the revenue is that of non-furnishing of audited AE and non AE segmental as well as documents regarding choice of foreign entity as tested party. We also noted that any other reason for levy of penalty is for non-furnishing of audited manufacturing and distribution of segmental accounts. Further, reason for levy of penalty is non-furnishing of documents on applicability of TNMM as per Rule 10D. We noted from the arguments of the learned Counsel for the assessee a

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