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2020 (5) TMI 571 - AT - Income TaxPenalty u/s 271BA - non- filing of report as required u/s 92E in respect of the international transactions - penalties thus proceed on the basis that there were ‘international transactions’ that the assessee had with its associated enterprises - HELD THAT:- We have held that the Kaybee Exim Pte Ltd, which is alleged to be an associated enterprises of the assessee, is not an associated enterprise of the assessee 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. The impugned penalties, therefore, must be deleted. - Decided in favour of assessee.
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