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2011 (4) TMI 677 - AT - Income TaxWhether rejection of the claim of deduction of expenditure on account of non-commencement of business is justified to levy penalty under section 271(1)(c) - Held that:- The assessee has surrendered the whole of the amount and abandoned the claim of the carry forward loss and even revised the return for subsequent year. However, the issue of allowability was a debatable issue. Mere rejection of the claim of deduction of expenditure on account of non-commencement of business would not be sufficient to satisfy the requirements of levy of penalty under section 271(1)(c).
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