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ITAT analyzed a penalty case under section 271AA involving non-reporting of an international transaction in Form 3CEB. The tribunal found that the transaction was a reimbursement through debit notes for assessment years 2009-10 to 2014-15, which the auditor did not consider an international transaction. Section 273B was applicable due to reasonable cause for non-reporting. The assessee had already declared the income in preceding years and the transaction was calculated per DRP directions. Consequently, ITAT held that no penalty was leviable under section 271AA, and the assessee was granted immunity. The appellate tribunal allowed the assessee's appeal, effectively quashing the penalty imposed by the jurisdictional CIT.
ITAT analyzed a penalty case under section 271AA involving non-reporting of an international transaction in Form 3CEB. The tribunal found that the transaction was a reimbursement through debit notes for assessment years 2009-10 to 2014-15, which the auditor did not consider an international transaction. Section 273B was applicable due to reasonable cause for non-reporting. The assessee had already declared the income in preceding years and the transaction was calculated per DRP directions. Consequently, ITAT held that no penalty was leviable under section 271AA, and the assessee was granted immunity. The appellate tribunal allowed the assessee's appeal, effectively quashing the penalty imposed by the jurisdictional CIT.
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