Penalty u/s 271(1)(c) - while declining deduction u/s 80IA no...

Penalty u/s 271(1)(c) - while declining deduction u/s 80IA no defect was pointed out by the A.O. with regard to assessee’s eligibility save and except there was delay in filing return of income - raising a bona fide legal claim, even if it is ultimately found to be legally not acceptable, could not amount to concealing particulars of income or furnishing of inaccurate particulars of income - no penalty