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2014 (1) TMI 1304 - ITAT DELHIPenalty u/s 271(1)(c) of the Act – Re-opening of Assessment - Held that:- Section 271(1)( c) does not envisage levy of penalty in respect of the issues where there is possibility of more than one interpretation and the additions made by the revenue are on account of difference of opinion about the provisions of the Act or in this case the treaty - Further, the fact that the appellant has not challenged the assessment order passed u/s 147 should not influence the decision while deciding that whether the appellant was liable for penalty u/s 271(1)( c) of the Act - The income of the assessee during re-assessment proceedings was not enhanced as is apparent from the assessment order and it was only the rate of tax which has been increased from 15% TO 20% - Since there is no change in the income declared and income assessed by the Assessing Officer, it cannot be said that there were any concealment of income – the order of the CIT(A) upheld – Decided against Revenue.
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