KEB HANA BANK,CHENNAI vs. JOINT DIRECTOR OF INCOME TAX, CHENNAI
In the result, all the appeals filed by the Reporting Entity are allowed
ITA 442/CHNY/2023[2020-2021]Status: DisposedITAT Chennai10 Aug 2023AY 2020-2021
Bench: Shri V. Durga Rao & Shri Manjunatha, G.आयकर अपील सं./I.T.A. Nos.440, 441 & 442/Chny/2023 िनधा"रण वष"/Assessment Years: 2018-19, 2019-20 & 2020-21 Keb Hana Bank, Vs. The Joint Director Of 4Th Floor, Bannari Amman Towers, Income Tax, Dr.R.K. Salai, Mylapore, Intelligence & Criminal Investigation, Chennai, Tamil Nadu 600 004. Chennai. [Pan:Aadck4261D] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Va Mehta, C.A. ""थ" की ओर से/Respondent By : Shri P. Sajit Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 12.07.2023 घोषणा की तारीख /Date Of Pronouncement : 10.08.2023 आदेश /O R D E R Per V. Durga Rao: These Three Appeals Filed By The Assessee Are Directed Against Separate But Identical Orders Of The Ld. Commissioner Of Income Tax (Appeals) 16, Chennai, All Dated 09.02.2023 Relevant To The Assessment Years 2018-19, 2019-20 & 2020-21 Passed Under Section 271Faa Of The Income Tax Act, 1961 [“Act” In Short] Levying Penalty Of ₹.50,000/- For Each Calendar Years 2017, 2018 & 2019. 2
For Appellant: Shri VA Mehta, C.AFor Respondent: Shri P. Sajit Kumar, JCIT
Section 271FSection 274Section 285B
u/s 271FAA was introduced to ensure due compliance to this 'Due diligence' requirement considering the seriousness of such reporting requirement as per the tax treaties with various countries on exchange of information.
The captioned assessee in appeal, a foreign bank was found, under reporting of certain reportable transactions of three Calendar years 2018, 2019 and 2020. This was detected during
