Cooperative Bank's Penalty for Missing AIR Filing Challenged; Bona Fide Belief Cited as Reasonable Cause u/s 273B.

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....Penalty u/s 271FA - not filing the AIR for the relevant AY - Prior to 01.04.2015 - the assessee being a Souhardha Sahakari, there was ambiguity as to whether Co-operative Banks are required to comply with the provisions of Rule 114E of the Rules, meaning thereby, the bonafide belief of the assessee would constitute a reasonable cause as mandated as per section 273B of the Act for the failure to furnish AIR for the relevant years under consideration. - AT....