TMI Blog2015 (6) TMI 532X X X X Extracts X X X X X X X X Extracts X X X X ..... 3 - - - Dated:- 20-4-2015 - Arun Tandon And Dr. Satish Chandra, JJ. For the Appellant : Dhananjay Awasthi,Bharat Ji Agarwal, Csc For the Respondent : Nishant Mishra ORDER The present appeal is filed by the department against the impugned order dated 28.06.2013 passed by the Income Tax Appellate Tribunal, Delhi in I.T.A. No. 2101/Del./2010 for the assessment year 2002-03, where ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... urt vide order dated 13.2.2013. (3) Whether on the facts and circumstances of the case, that ITAT erred in law in concluding that no penalty is leviable as tax sought to be evaded as NIL totally ignoring that the NIL income was after adjustment and no tax was paid on the returned income and entire amount of TDS was claimed as refundable. (4) Whether on the facts and circumstances of the case ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nd partly in Foreign currency. Revenues arising to Technip from on shore construction, on shore design and engineering, on shore supply, off shore construction and off shore design and engineering were offered to tax in India by Technip. The revenues from off shore supply of equipment were not considered to be chargeable to tax in India. But the A.O. has not accepted this plea and made the addit ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ITR 158 (SC); and (3) CIT Vs. Amit Jain, 213 (351) ITR 74 (Del.). In the abovementioned cases, it was held that the assessee had a bona-fide belief regarding the manner of income on account of design and engineering fees. There is no dispute that the computation of income was duly disclosed by the assessee and accepted by the A.O. In these circumstances, the entire addition was deleted by bo ..... X X X X Extracts X X X X X X X X Extracts X X X X
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