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2012 (11) TMI 178 - ITAT, PUNEPenalty under section 271(1)(c) of the Income-tax Act - addition made to ‘book profits’ under Section 115JB of the Act – Held that:- Provision for bad and doubtful debts which has been disallowed by the Assessing Officer on the ground that the same was contingent in nature - assessee has pointed out that it was under bonafide belief that the Provision for bad and doubtful debts debited in the Profit and Loss Account is not a provision for liability but a diminution in the value of assets and therefore it was allowable while computing ‘book profits’ as per Section 115JB of the Act - no default within the meaning of 271(1)(c) of the Act can be attributed to the assessee - at the time of filing of return the issue in question was debatable where two view were possible and therefore such a claim made in return of income, though found untenable by the Assessing Officer, cannot be construed as furnishing of inaccurate particulars of income within the meaning of Section 271(1)(c) of the Act – in favor of assessee
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