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    <title>2024 (7) TMI 395 - ITAT BANGALORE</title>
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    <description>ITAT Bangalore held that penalty under section 271D was not leviable against the assessee who accepted cash payments from buyers unable to arrange demand drafts due to restricted banking hours. The tribunal found the penalty was not initiated within reasonable time, as the return filed in August 2017 was processed in September 2017, but penalty notice was issued only in July 2021. The tribunal noted this was the first year after amendment introduction, buyers provided confirmations of inability to obtain demand drafts, and revenue selectively targeted the assessee while sparing others in the same transaction, violating Article 14. Penalty deleted in assessee&#039;s favor under section 273B.</description>
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      <title>2024 (7) TMI 395 - ITAT BANGALORE</title>
      <link>https://www.taxtmi.com/caselaws?id=755175</link>
      <description>ITAT Bangalore held that penalty under section 271D was not leviable against the assessee who accepted cash payments from buyers unable to arrange demand drafts due to restricted banking hours. The tribunal found the penalty was not initiated within reasonable time, as the return filed in August 2017 was processed in September 2017, but penalty notice was issued only in July 2021. The tribunal noted this was the first year after amendment introduction, buyers provided confirmations of inability to obtain demand drafts, and revenue selectively targeted the assessee while sparing others in the same transaction, violating Article 14. Penalty deleted in assessee&#039;s favor under section 273B.</description>
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