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2019 (2) TMI 55 - AT - Income TaxPenalty u/s 271AA - scope of amendment - assessee discussed the provision u/s 271AA of the Act as it stood relevant to the year under consideration and its substitution thereafter w.e.f. 01.04.2014 - Held that:- We find that it was rightly pointed out by the Ld.AR that the entire provision was substituted vide Finance Act, 2012 w.e.f. 01.07.2012 thereby prima facie the said provision is not applicable to the present case. AO primarily imposed penalty u/s 271AA of the Act only on the condition that the assessee reported “no international transaction in its return of income”. But, however, the CIT(A) discussed the same in its order at page No.11 and observed during the year under consideration the requirement is to keep and maintain any such information/document in respect of international transaction and no such condition to impose penalty on failure of reporting international transaction in the return of income. Therefore, we find no infirmity in the order of CIT(A) and it is justified for the reasons stated in his order which is reproduced herein above. - Decided against revenue
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