Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2015 (5) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2015 (5) TMI 1109 - ITAT MUMBAIPenalty u/s.271(1)(c) - 50% of revenues attributable to India-Royalty income, 25% of revenues attributable to India-FTS and 70% of revenues attributable to India- Business Income - Held that:- Assessment has been made on the basis of difference of opinion regarding the interpretation of law on the question of PE, existence of agency PE, royalty and FTS. There is no concealment of any fact nor have any additional facts been discovered proving the earlier disclosure in the return to be false or wrong. The findings recorded by the CIT(A) are just and proper and after consideration of various judicial pronouncements. Respectfully following the order of the Tribunal in assessee’s own case, which has been upheld by the Hon’ble Bombay High Court as well as the judgment of the Hon’ble Supreme Court in the case of Reliance Petroproducts Ltd. (2010 (3) TMI 80 - SUPREME COURT ), we see no reason to interfere in the findings of the CIT(A) deleting the penalty so levied by the AO. - Decided against revenue
|