Section 271FA penalty not leviable in absence of reportable transaction

M/s Guntur District Co-operative Central Bank Ltd. Vs Director of Income Tax (ITAT Visakhapatnam)

Conclusion: Penalty under 271FA was unjustified as there was no requirement to file the AIR in absence of reportable transaction during the financial year and also, department did not make out a case that the assessee had the recorded re portable transactions in the relevant financial year.

Held: In the instant case, assessee did not file the AIR for the F.Y.

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