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2015 (10) TMI 5 - AT - Income TaxPenalty u/s. 271(1)(c) - arrear rent receipts - Held that:- As seen that the amount received by the assessee was compensation for illegal occupation of the premises by the Ministry of Defence. The appellant has stated that there was no fraud or concealment of any income and all the facts had been disclosed truly and correctly before the authorities and the Hon’ble Courts. It has been stated that addition was made only on account of difference of interpretation between the Department and the assessee. It is seen that in the present case that there is no concealment of facts or filing of inaccurate particulars. There exist no conditions which should attract penal provisions. It is also seen that all the relevant and material facts are well within the knowledge of the department, High Courts and other authorities. It was the Ld. CIT(A) observation that this is a case where there is only a difference of interpretation and opinion. Hence, it is felt that these cases do not fall within the purview of section 271(1)(c). Hence, the penalty imposed is deleted - Decided in favour of assessee.
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