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2012 (2) TMI 514 - HC - Income TaxPenalty under Section 271(1)(c) - disallowance u/s 14A - ITAT confirming the deletion of penalty - Held that:- Disallowance under the said Section have been subject matter of debate and different views have been expressed. A legal contention which was plausible and merited consideration was raised. Accordingly, the appellate authorities have applied the explanation to Section 271(1)(c) of the Act. Looking at the nature of explanation offered and the provision in question i.e. Section 14A, which was incorporated by the Finance Act, 2001 with retrospective effect from 1st April, 1962, we do not think in the present case any substantial question of law arises in view of the factual matrix involved. Accordingly, the appeal of revenue dismissed.
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