2015 (6) TMI 326

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..... ssue. All this indicates that there were two views possible on the issue and before it was settled by a special Bench decision of the Tribunal. Thus, on a debatable point and legal issue, a penalty could not have been imposed and the ingredients of section 271(1)(c) of the Income Tax Act are not attracted in such cases. This is essentially a finding of fact and clearly emerging from the admitted p .....

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..... unable to agree with Mr. Tejveer Singh. In paragraph 23 of the order passed by the Tribunal and impugned in this appeal, it is held that there were two disallowances by the Assessing Officer viz. under section 40(a)(i) to the tune of ₹ 14.92 crores and second income of Head Office / Branch Office at ₹ 14.92 crores. In a composite order whereby these disallowances were made, the Assess .....

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