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of ITAT reversed penalty imposed under s271I for non-submission of Form 15CA/15CB regarding overseas transactions. Following precedent in M/s Vinay Diamond matter, tribunal acknowledged CBDT Notification GSR 978(E) which exempts certain payments from Form 15CA/15CB filing requirements. Specifically, advance payments against imports fall under exempted categories per Rule 37BB. Tribunal concluded penalty cannot be levied for import-related payments, ruling in appellant's favor. Decision reinforces regulatory exemptions for specified international transactions and clarifies compliance obligations for cross-border advance payments.
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