https://www.taxtmi.com/caselaws?id=794890 Penalty for non-reporting an international transaction is not sustainable where reasonable cause supports a bona fide belief that the transaction was outside India's taxable and reportable scope. Sale of raw materials directly from Korea, without demonstrated nexus to the Indian project office or profit attribution in assessment, supported deletion of the penalty. Appellate enhancement of a penalty cannot introduce guarantee-fee and trade-affairs-service transactions that were not part of the original penalty proceedings. The penalty was deleted in full, and the related stay application became infructuous. en-us Mon, 25 May 2026 00:00:00 +0530 Tue, 14 Jul 2026 08:26:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794890 Penalty for non-reporting an international transaction is not sustainable where reasonable cause supports a bona fide belief that the transaction was outside India's taxable and reportable scope. Sale of raw materials directly from Korea, without demonstrated nexus to the Indian project office or profit attribution in assessment, supported deletion of the penalty. Appellate enhancement of a penalty cannot introduce guarantee-fee and trade-affairs-service transactions that were not part of the original penalty proceedings. The penalty was deleted in full, and the related stay application became infructuous. Case-Laws Income Tax Mon, 25 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794890