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The Tax Publishers Mayar India Ltd. v. Dy. CIT [ITA No. 1872/Del/2014, dt. 26-4-2016] : 2016 TaxPub(DT) 2210 (Del-Trib) Levy of penalty under section 271G due to delay in submitting TP documentation Facts: Assessee had AE transactions on which submissions were made belated but no ALP additions were made. Subsequently penalty was levied mechanically under section 271G for 34 lakhs which was upheld by Commissioner (Appeals) for belated receipt of TP documentation. On appeal: Held in favour of the assessee that penalty is uncalled for, as the order of penalty does not specify how the belated receipt happened or impacted the ALP computation when no additions were made in the ALP. Similar case but in a more detailed reading arose in - Flash mailer 255 Worlds Window Impex (India) Pvt. Ltd. v. ACIT/ITA No.3721/Del/2014/assessment year 2009-10/Del ITAT/Dated 22-4-2016
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