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TMI Blog2018 (10) TMI 1300X X X X Extracts X X X X X X X X Extracts X X X X ..... L KURESHI) 1. Revenue is in appeal against the judgment of the Incometax Appellate Tribunal dated 22.8.2017 raising following question for our consideration. "A. Whether the Appellate Tribunal is correct in law and in fact in upholding the decision of the ld. CIT(A) and deleting the penalty of Rs. 67,26,000/u/ s.271(1)(c) of the Act levied on account of concealment of income by way of wrong cl ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... issue involved is complex and debatable in nature. 8. After perusal of the orders of the authorities below and after taking note of rival submissions, we are unable to find any infirmity in the conclusion drawn by the CIT(A). The CIT(A) has taken note of the relevant facts while adjudicating the issue in favour of assessee. As can be seen, the cause of action arose on account of modification o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hat the issue pertains to valuation of leasehold rights as on 1.4.1981. The Assessing Officer did not accept valuation adopted by the assessee and made corresponding additions. We notice that on merits itself substantial additions were deleted by higher authorities. Thus the issue itself was highly debatable and substantially fact based. In background of such facts the Tribunal held that this is n ..... X X X X Extracts X X X X X X X X Extracts X X X X
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