Section 271FA — the law in short
What the courts have decided on section 271FA, in one screen. Read this first; open an entry when you need the facts, the reasoning and the source.
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Guntur District Co-operative Central Bank Ltd v DIT
ITATCuts both ways
We had no reportable transactions and filed no SFT. Can they still levy penalty under 271FA?
No, not for a year in which there was nothing to report. Section 285BA casts the filing obligation on a person who has registered or recorded a specified financial transaction during the financial year, so where no such transaction exists the duty to furnish the statement never arises and s.271FA has nothing to bite on. The burden is on the department to show that reportable transactions were in fact recorded before it can allege a failure.
Listed strongest first: Supreme Court, then High Court, then Tribunal, then CBDT. Nothing here has yet been read in full by a chartered accountant — open an entry to see where it came from.