TMI Blog2017 (8) TMI 1356X X X X Extracts X X X X X X X X Extracts X X X X ..... by the Assessee warranting the levy of penalty. No substantial question of law arises - ITA No. 294/2016 - - - Dated:- 22-8-2017 - JUSTICE S. MURALIDHAR AND JUSTICE PRATHIBA M. SINGH For the Appellant : Mr. Ashok K. Manchanda, Mr. Raghvendra Singh, Senior Standing Counsel for Revenue. For the Respondent : Mr. Rohit Jain Mr. Aniket D. Agarwal, Advocates. ORDER 1. This ap ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... held by the Supreme Court in its decision in Punjab State Industrial Development Corporation Ltd. v. CIT [1997] 225 ITR 792 (SC). 5. The ITAT has, in the impugned order, referred to the decision in CIT v. Reliance Petroproducts Pvt. Ltd. [2010] 322 ITR 158 (SC) in coming to the conclusion that this was not a case of concealment of material particulars which would warrant a levy of penalty. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the assessment order under Section 263 of the Act. 8. Having considered the submissions of the learned counsel of the parties, the Court is of the view that the decision of the ITAT was a plausible one in the facts and circumstances of the case. The Court is unable to agree with the Revenue that there is a deliberate concealment by the Assessee warranting the levy of penalty. 9. No substant ..... X X X X Extracts X X X X X X X X Extracts X X X X
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