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    <title>2025 (1) TMI 870 - ITAT AHMEDABAD</title>
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    <description>The ITAT Ahmedabad ruled in favor of the assessee regarding penalty under Section 271BA for failure to file Form 3CEB report under Section 92E before the due date. The tribunal found that the assessee had prepared Form 3CEB on 16.10.2016, prior to the search conducted on 19.11.2019, and filed it before the TPO during reference proceedings. The ITAT held that the failure to file was inadvertent rather than deliberate, as the form was already compiled per Income Tax Act procedures. Consequently, the penalty under Section 271BA was deleted and the assessee&#039;s appeal was allowed.</description>
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    <pubDate>Thu, 16 Jan 2025 00:00:00 +0530</pubDate>
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      <title>2025 (1) TMI 870 - ITAT AHMEDABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=764806</link>
      <description>The ITAT Ahmedabad ruled in favor of the assessee regarding penalty under Section 271BA for failure to file Form 3CEB report under Section 92E before the due date. The tribunal found that the assessee had prepared Form 3CEB on 16.10.2016, prior to the search conducted on 19.11.2019, and filed it before the TPO during reference proceedings. The ITAT held that the failure to file was inadvertent rather than deliberate, as the form was already compiled per Income Tax Act procedures. Consequently, the penalty under Section 271BA was deleted and the assessee&#039;s appeal was allowed.</description>
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