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2009 (11) TMI 57 - PUNJAB AND HARYANA HIGH COURTPenalty u/s 271(1)(c) - ITAT hold that the issue of taxability of compensation on agricultural land and interest thereon received by the assessee being a highly debatable issue on which two views are clearly possible and the claim of the assessee in adopting one possible view being bonafide one, no case of penalty u/s 271 (1) (c ) of the Act could be made out - The question is not of taxability but of not paying tax when the issue was debatable. The assessee had arguable case and earlier view was in favour of the assessee in CIT v. Karanbir Singh, which is based on the judgment of the Hon'ble Supreme Court in CIT v. Hindustan Housing and Land Development Trust Ltd., which has now been reversed in Ghanshyam – penalty not to be impsoed
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