No Penalty for Non-Filing Form 3CEB: Genuine Misunderstanding of Section 139D(c) Deemed Reasonable Cause u/s 273B.

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....Penalty u/s 271BA - non-filing of audit report in Form 3CEB - international transactions - the expression "May" used in section 271BA needs to be viewed liberally - in view of the reasoning given by the assessee due to bonafide mistaken understanding of provisions contained in section 139D(c) which itself would determine reasonable cause in terms of section 273B - no penalty - AT....