Penalty for failure to furnish information or document under section 92D.

If any person who has entered into an 2[international transaction or specified domestic transaction] fails to furnish any such information or document as required by sub-section (3) of section 92D, the Assessing Officer 3[or the Transfer Pricing Officer as referred to in section 92CA] or the Commissioner (Appeals) may direct that such person shall pay, by way of penalty, a sum equal to two per cent of the value of the 2[international transaction or specified domestic transaction for each such failure.]