Substantial question of law absent in penalty deletion dispute; Revenue's Section 260A challenge failed on concurrent findings.

The Revenue's Section 260A appeal against deletion of penalty under Section 271(1)(c) failed because the Commissioner (Appeals) and the Tribunal had reached concurrent conclusions on the same reasoning, and no legal infirmity was shown in those orders. The Court found no substantial question of law arising from the record and therefore declined interference. The penalty deletion was sustained, and the appellate challenge could not succeed on merits.

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Issues: Whether the Revenue's appeal under Section 260A of the Income-tax Act, 1961 was maintainable in view of the concurrent orders deleting the penalty imposed under Section 271(1)(c) of the Income-tax Act, 1961.

Analysis: The penalty deletion had been affirmed by the Commissioner (Appeals) and the Tribunal on concurrent reasoning. No legal infirmity was found in those orders, and the Court found no basis to interfere. In the absence of any substantial question of law, the appellate challenge could not succeed.

Conclusion: The appeal was not maintainable on merits and the penalty deletion was sustained.

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