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2019 (11) TMI 1035 - ITAT DELHIPenalty u/s.271(1)(c) - addition of leasehold improvement which was claimed as Revenue expenditure and treated as capital in nature by the Assessing Officer - HELD THAT:- As decided in own case [2012 (9) TMI 261 - ITAT DELHI] it was a clear case of difference of opinion with respect to claim of assessee. Mere non filing of appeal by assessee against the additions made by AO cannot be said to be admission by assessee of having submitted wrong claim. In view of the above, we are of the considered opinion that penalty imposed by AO and upheld by the Ld. CIT (A) is not justified. - Decided in favour of assessee.
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