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Sec. 271G of Income Tax Act, 1961— Penalty - When the statutory provisions confer enough power on the Transfer Pricing Officer to benchmark the international transaction as per the provisions of the Act, the allegation of the Transfer Pricing Officer that by non-furnishing of documents by the assessee he was prevented from determining the arm's length price under CUP method is unacceptable, therefore, when the Transfer Pricing Officer has accepted the benchmarking of the assessee, the imposition of penalty under section 271G is unsustainable - DEPUTY CIT V/s DECENT DIA JEWELS PVT. LTD. -  183 ITD 492 (ITAT-MUMBAI)