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The jurisdictional HC in the case of Schneider Electric South Asia (HQ) PTE. Ltd. vs. ACIT held that the mere reference to "misreporting" without specifying the limb of Section 270A attracted or satisfying the ingredients of subsection (9) renders the order imposing penalty u/s 270A(9)(a) manifestly arbitrary. Consequently, the levy of penalty u/s 270A(9)(a) was deleted in favor of the assessee.
The jurisdictional HC in the case of Schneider Electric South Asia (HQ) PTE. Ltd. vs. ACIT held that the mere reference to "misreporting" without specifying the limb of Section 270A attracted or satisfying the ingredients of subsection (9) renders the order imposing penalty u/s 270A(9)(a) manifestly arbitrary. Consequently, the levy of penalty u/s 270A(9)(a) was deleted in favor of the assessee.
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