TMI Blog2011 (7) TMI 522X X X X Extracts X X X X X X X X Extracts X X X X ..... e quantum addition in the present case and the same is pending - Held that:- The fact that the appeal against the deletion of the quantum addition is pending before this Court, cannot be a ground to sustain the penalty imposed under Section 271(1)(c) because the quantum addition itself was made on the basis of the return filed by the assessee which is found to be correct. Merely because the assess ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ia and Ireland. The Assessing Officer disagreed with the contention of the assessee and taxed the royalty income at Rs.62.21 lakhs and levied penalty under Section 271(1)(c) of the Income Tax Act, 1961. 4. The Commissioner of Income Tax (Appeals) deleted the penalty on the ground that the assessment has been made on the basis of the facts disclosed by the assessee. The Tribunal confirmed the o ..... X X X X Extracts X X X X X X X X Extracts X X X X
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