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2014 (7) TMI 1189 - AT - Income TaxPenalty u/s 271(1)(c) - Held that:- Respectfully following the above decisions of Hon’ble Jurisdictional High Court of Delhi in the case of Liquid Investment Ltd. (2010 (10) TMI 1021 - DELHI HIGH COURT ) and other relevant decisions we are inclined to hold that the penalty was imposed on the assessee pertaining to the issue on which a substantial question of law has been framed by Hon’ble High Court and the same has become debatable then no penalty is leviable thereon. Accordingly, we hold that the AO was not justified in imposing penalty and the CIT(A) confirmed the same without any basis and justified ground which is not sustainable in view of foregoing discussions. Resultantly, the sole ground of assessee is allowed.
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