Filing of revised return in anticipation of proposed adjustment by TPO won’t escape penalty

IT/ILT : Where subsequent to reference made by Assessing Officer to TPO for determination of ALP relating to transaction of reimbursement of expenses incurred in respect of services availed from AE, assessee filed a revised return making disallowance of entire marketing expenses, since said revision was made in anticipation of proposed adjustment, it could not be regarded as voluntary and bona fide and, thus, authorities below rightly passed penalty order under section 271(1)(c) on basis