Case Number: ITA No. 798/DEL/2020
Assessment Year: 2007-08
Appellant: Brown Multi Wall Paper Bags Limited Through Its Resolution Professional, Mumbai
Respondent: ITO, Ward-5(2), New Delhi
The appeal was filed against the Commissioner of Income Tax (Appeals)’s order relating to penalties under section 271G due to non-compliance with documentation requirements under section 92CA(3). Despite multiple notices, the company did not comply with the documentation requests, leading to a substantial penalty.
The Tribunal noted that the penalty was based on the value of specified domestic transactions and found the company’s non-compliance with documentation requests to be unjustified. Despite the company’s argument regarding the acceptance of their transfer pricing report, the Tribunal emphasized the importance of compliance with all procedural requirements under the Income Tax Act.
The case highlights the stringent enforcement of documentation requirements in transfer pricing cases and the significant penalties for non-compliance. This decision serves as a cautionary tale for other corporations about the importance of adhering to procedural norms and requirements under the Tax laws.
Presiding Members:
The decision underscores the rigorous application of tax laws and the emphasis on maintaining thorough documentation for all significant transactions.
Case Analysis: Brown Multi Wall Paper Bags Ltd. vs. ITO, Ward-5(2), ITA No. 798/DEL/2020
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