TMI Blog2014 (3) TMI 1174X X X X Extracts X X X X X X X X Extracts X X X X ..... me. The penalties were confirmed by the CIT (Appeals). The Tribunal cancelled them on the ground that questions of law have been framed by this Court in the appeals filed by the assessee in the assessment proceedings, which indicated that the issue was debatable. Tribunal after considering these circumstances and relying upon CIT vs. HB Leasing and Finance Co. Ltd [ 2011 (2) TMI 434 - DELHI HI ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 830/- and ₹ 1,02,82,883/- for the assessment years 1993-94 and 1994-95 respectively, against its taxable profits from the Faridabad unit; the interest was paid to the Noida unit whose profits were exempted from tax under Section 10A. The assessing officer took the view that no exemption can be given to the Noida unit in respect of the interest income and also initiated proceedings for the le ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ted in Commissioner of Income Tax vs. Liquid Investment and Trading Co., ITA No.240/2009 decided on 05.10.2010. On that occasion the Court recorded as follows: - Both the CIT(A) as well as the ITAT have set aside the penalty imposed by the Assessing Officer under Section 271(1)(c) of the Income Tax Act, 1961 on the ground that the issue of deduction under Section 14A of the Act was a debatable ..... X X X X Extracts X X X X X X X X Extracts X X X X
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