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Director of Income Tax (IT) -I Versus M/s Sumitomo Mitsui Banking Corpn.

2015 (6) TMI 326 - BOMBAY HIGH COURT

Penalty under section 271(1)(c) - disallowances under section 40(a)(i) and income of Head Office / Branch Office - ITAT deleted penalty levy - Held that:- On the merits of the disallowances have not been accepted and the special Bench had to be const .....

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osed 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 position. In the circumstances, the Tribunal's direction to delete the p .....

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Sheth & Mr Atul K Jasani ORDER P.C. 1. This appeal of the Revenue challenges the order passed by the Income Tax Appellate Tribunal deleting a penalty in the sum of ₹ 8,56,72,539/- imposed by the Assessing Officer under section 271(1)(c) of .....

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raph 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 O .....

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