https://www.taxtmi.com/caselaws?id=752049 Penalty under section 271BA was held unsustainable where the assessee acted under a bona fide belief that its India-sourced royalty income had already suffered tax deduction at source, filed the return in response to notice under section 148, and furnished the accountant's report under section 92E during assessment proceedings. As the assessment was completed at the returned income under section 143(3) read with section 147 and no transfer pricing adjustment was made, the non-furnishing of the report at the initial stage was not treated as a fit case for penalty. The penalty was directed to be deleted. en-us Tue, 30 Apr 2024 00:00:00 +0530 Thu, 02 May 2024 08:23:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=752049 Penalty under section 271BA was held unsustainable where the assessee acted under a bona fide belief that its India-sourced royalty income had already suffered tax deduction at source, filed the return in response to notice under section 148, and furnished the accountant's report under section 92E during assessment proceedings. As the assessment was completed at the returned income under section 143(3) read with section 147 and no transfer pricing adjustment was made, the non-furnishing of the report at the initial stage was not treated as a fit case for penalty. The penalty was directed to be deleted. Case-Laws Income Tax Tue, 30 Apr 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=752049