Assessee-firm had entered into an international transaction. The  assessee had not furnished report of accountant as required under section 92E of the Act.  Assessing Officer levied penalty u/s 271BA of the Act.  Assessee contended that they were ignorance in regard to legal requirement and had submitted that word ‘Specified Domestic Transaction’ was inserted in section 92E by Finance Act, 2012, w.e.f. 1-4-2013 which was applicable for first time from assessment year 2013-14 and though assessee obtained Form 3CEB from Chartered Accountant but had failed to upload same electronically, as it was not aware about recent changes and amendments in provision. Further, there were no adjustments made by TPO and he accepted returned income as assessed income and, thus, there was no mala fide in said transaction. Allowing the appeal the Tribunal held that   non-uploading of Form 3CEB for first time, being an unintentional bona fide mistake, penalty order confirming was to be set aside. (AY. 2013-14)