Penalty u/s 271G Unjustified if Assessing Officer Has Doubt; Actus Reus Must Be Clearly Proven.

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....Penalty u/s 271G - filing of document within two months before Transfer pricing officer (TPO) - Ambiguity or doubt in the mind of the Assessing Officer does not justify imposition of penalty, when the actus reas itself is not proved and established. - HC....