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2019 (2) TMI 1673 - AT - Income TaxPenalty u/s 271AAA - assessee had surrendered additional income - diversified views - HELD THAT:- When two views are possible on an issue, the view which is favourable to the assessee has to be accepted in view of the decision of the Hon’ble Apex Court in the case of vegetable products Ltd [1973 (1) TMI 1 - SUPREME COURT]. The Tribunal further noted that since the assessee had surrendered additional income by paying the taxes due thereon and no specific query was raised by the search party at the time of search, following the decision of the Hon’ble Gujarat High Court and various other decisions relied upon by the Ld. CIT(A) the penalty cannot be sustained. - Decided against revenue.
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