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TMI Blog2017 (5) TMI 1624X X X X Extracts X X X X X X X X Extracts X X X X ..... 321 - DELHI HIGH COURT] reference was not made to any particular or specific date by which assessee was required to submit the documents; or whether the same were furnished within 30 days or within the extended period of 30 days thereafter - Penalty u/s 271G cannot be imposed in this manner. A specific finding should be recorded on the date by which the assessee was required to furnish document ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... urana Ms. Archana JUDGMENT Per Hon ble Jhaveri, J. 1. By way of this appeal, the appellant has challenged the judgment and order of the Tribunal whereby the Tribunal has dismissed the appeal of the revenue. 2. Counsel for the appellant has framed the following substantial question of law: Whether the Tribunal was legally justified in cancelling the penalty levied under Sectio ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... er. A specific finding should be recorded on the date by which the assessee was required to furnish documents and whether documents were furnished, if not which documents were not furnished and whether any extension of time was granted by the Transfer Pricing Officer and if the required documents were then actually filed. The penalty order is bereft and devoid of the said details and, therefore, s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... filed on record by the Revenue along with the present grounds of appeal. We do not know what was requisitioned and asked for by the said notice and which/what documents and details were supplied. We also do not know whether any extension of time was prayed for or granted by the Transfer Pricing Officer and whether any hearing was fixed by the Transfer Pricing Officer pursuant to notice dated 12.0 ..... X X X X Extracts X X X X X X X X Extracts X X X X
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