2014 (6) TMI 970

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..... the Respondent/ Assessee.   P.C.: 1 These Appeals by the Revenue challenge the common order passed by the Income Tax Appellate Tribunal. Two Appeals which have been dealt with by the Tribunal are of the Assessee. They impugned the orders passed by the Commissioner of Income Tax (Appeals) dated 22.12.2008 and 02.01.2009 whereunder the Commissioner of Income Tax (Appeals) confirmed the penalt .....

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..... the return of income while making the claim in respect of frontend fees were incorrect or erroneous or false. The Assessee has disclosed in its return of income that the amount of front end fees to be non taxable in India. The note was also annexed to the return giving the basis for which the claim was made. In these circumstances whether the Assessee's stand was justified or otherwise, surel .....

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