Penalty u/s 271BA - non furnishing of Report u/s 92E - in Section 271BA words used is “may” and not...

Penalty u/s 271BA - non furnishing of Report u/s 92E - in Section 271BA words used is “may” and not “shall”, thereby making intentions clear that levy of penalty is discretionary and not automatic - it was the first year for the assessee and same was filed in the assessment proceedings itself - even otherwise qua the domestic transactions with its sister concern no additions made by the AO/TPO - bonafide mistake - no penalty .....

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