Penalty u/s 271BA - admittedly the assessee failed to upload...

Penalty u/s 271BA - admittedly the assessee failed to upload Form No. 3CEB in terms of the statutory requirement - Specified Domestic Transaction - Assessee contended that, this being the first year of this new provision it could not upload the same electronically which is neither willful nor wanton. - The assessee has further pleaded that based on the report, no adjustments have been proposed by the TPO. - Non uploading of Form 3CEB for the first time is an unintentional bona fide mistake. - Levy of penalty deleted - AT