During the course of assessment, based on the material or information or documents in his possession, assessing officer is of the opinion that the arm length price determined by enterprise is not reliable or correct & is resulting in lower profit (or increase in loss), the officer has right to determine correct ALP based on above information & following consequences will follow :
Section 271AA - Penalty for non maintenance of prescribed record/ documents: Prescribes for imposition of penalty equal to 2% of the value of each international transaction on account of failure to maintain information & document
Section 271BA - Penalty for failure to submit audit report within prescribed time limit: Penalty equal to Rs.1, 00,000 for failure to furnish audit report from an accountant as required u/s 92E
Section 271G - Penalty for failure to submit records / documents called for: Penalty of 2% of the value of international transaction for each failure to produce information & document as requisitioned by Income tax authorities
This section provides that every person who has entered into an IT during a previous year shall obtain a report from an accountant in prescribed form & submit the same to income tax authority before prescribed date.
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