Penalty for Non-Filing Report u/s 271BA Dismissed; No International Transactions Found with Alleged Associated Enterprise.

Penalty u/s 271BA - non- filing of report as required u/s 92E - Once we hold that the assessee and the alleged AE could not be treated as associated enterprises, and there are no other alleged ‘international transactions’ on the facts of this case, it could not be said that the assessee had entered into any international transactions. As a corollary to this finding, the very foundation of impugned penalties ceases to hold good in law. - No penalty. .....

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