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2019 (9) TMI 545 - AT - Income TaxPenalty u/s. 271(1)(c) - disallowance of deduction u/s. 80IA on profit from DEPB and computation of book profit u/s. 115JB - debatable issues - HELD THAT:- Assessee had disclosed all relevant particulars for computation of its income. All the relevant facts were already before AO. The issues on which additions were made were debatable and the instant case of the assessee was a case of bonafide difference of opinion on the entitlement of deduction as per provision of the Act. The assessee had also disclosed the compete facts of merger and its claim of deduction u/s. 115JB of the Act. We uphold the findings of the ld. CIT(A) that the assessing officer has not established that the assessee furnished incorrect facts after placing reliance on the decision of CIT vs. Reliance Petro products Pvt. Ltd. [2010 (3) TMI 80 - SUPREME COURT].- Appeal of the Revenue is dismissed.
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