Amalgamation disputes under Section 269SS: ITAT deletes Penalty u/s 271D

DCIT Vs Trans Asia Packaging Ltd (ITAT Delhi) Introduction: The Income Tax Appellate Tribunal (ITAT), Delhi, in the case of DCIT Vs Trans Asia Packaging Ltd, addressed a crucial issue relating to transactions between amalgamated companies. The ITAT held that transactions between two units of a single entity post amalgamation cannot be considered as infringing Section 269SS of the Income Tax Act, thereby deleting the penalty imposed under Section 271D. Analysis: The case in question revolved around a penalty imposed on Trans Asia Packaging Ltd. (TAPL) under Section 271D of the Act for allegedly...