https://www.taxtmi.com/caselaws?id=794890 Penalty under section 271AA may be avoided where a taxpayer has reasonable cause under section 273B and a bona fide belief that an international transaction, undertaken outside the Indian project office or permanent establishment, was not taxable or reportable in India. Relevant factors include the absence of a demonstrated nexus with India, no income addition or profit attribution, and arm's-length acceptance of the associated enterprise transaction. The notes also address the limits of appellate enhancement under section 251(1)(b), indicating that additional transactions not examined in the original penalty proceedings, such as guarantee fees or trade affairs services, should not be introduced as a new penal subject matter. 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 under section 271AA may be avoided where a taxpayer has reasonable cause under section 273B and a bona fide belief that an international transaction, undertaken outside the Indian project office or permanent establishment, was not taxable or reportable in India. Relevant factors include the absence of a demonstrated nexus with India, no income addition or profit attribution, and arm's-length acceptance of the associated enterprise transaction. The notes also address the limits of appellate enhancement under section 251(1)(b), indicating that additional transactions not examined in the original penalty proceedings, such as guarantee fees or trade affairs services, should not be introduced as a new penal subject matter. Case-Laws Income Tax Mon, 25 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794890