TMI Blog2017 (1) TMI 1594X X X X Extracts X X X X X X X X Extracts X X X X ..... by the AO. The CIT(A) took note of the same in the intervening period as well as of the judgment of the Supreme Court in K. C. Builders v. ACIT [2004 (1) TMI 7 - SUPREME COURT] and deleted the penalty. The ITAT has confirmed that order. As is evident from the factual narrative, the primary question of disallowance itself was debatable – in appeal to the ITAT the assessee was successful. In the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... adverse order and disallowance under Section 40(a)(i) of the Income Tax Act. Consequent to this disallowance, penalty proceedings were initiated culminating in an adverse order. The main disallowance was carried in appeal to the CIT(A) who granted the relief. The ITAT confirmed that order. It is pointed out by the Revenue, at the outset, that its appeal against the deletion of disallowance is pend ..... X X X X Extracts X X X X X X X X Extracts X X X X
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