https://www.taxtmi.com/caselaws?id=464631 ITAT Mumbai allowed the assessee's appeal and directed deletion of the penalty under section 271AA. The Tribunal held that the deeming clauses of s.92A establish associated enterprise status only under specified subclauses, and the assessee had a reasonable cause under s.273B-grounded in a bona fide view (supported by an article) that the foreign counterparty was not an AE-to omit records under s.92D. Further, since the AO confined assessment to s.40A(2) and did not treat the transaction as between AEs, s.92D and consequently s.271AA were inapplicable. en-us Wed, 07 Nov 2012 00:00:00 +0530 Sat, 08 Nov 2025 10:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=464631 ITAT Mumbai allowed the assessee's appeal and directed deletion of the penalty under section 271AA. The Tribunal held that the deeming clauses of s.92A establish associated enterprise status only under specified subclauses, and the assessee had a reasonable cause under s.273B-grounded in a bona fide view (supported by an article) that the foreign counterparty was not an AE-to omit records under s.92D. Further, since the AO confined assessment to s.40A(2) and did not treat the transaction as between AEs, s.92D and consequently s.271AA were inapplicable. Case-Laws Income Tax Wed, 07 Nov 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=464631