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2015 (11) TMI 1383 - AT - Income TaxPenalty under section 271(1)(c) - CIT(A) deleted penalty - Held that:- The assessee has given reasonable details showing confirmation by the lender, bank statement details etc. while such evidences may not prove the genuineness of the transaction to the hilt , these evidences do indeed show prima facie bonafides of the assessee. These evidences have not been found to be false, incorrect or doubtful. In these circumstances, mainly because the assessee has not been able to give details of lender’s Assessing Officer, the explanation of the assessee cannot indeed be rejected. The assessee also has a reasonable explanation for not pursuing the quantum addition in appeal as the related quantum addition is completely tax neutral. In view of these discussions, as also bearing in mind entirety of the case, we approve well reasoned conclusion arrived at by the learned CIT(A) and decline to interfere in the matter. - Decided in favour of assessee.
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