Penalty u/s 271(1)(c) - Exemption u/s 11 - CIT(A) has...

Penalty u/s 271(1)(c) - Exemption u/s 11 - CIT(A) has categorically observed that no evidence had been brought on record to adduce that furnishing of inaccurate details had been done by the Assessee wilfully, in order to avoid the payments of tax, or to conceal the particulars of income. - It is clear that the penalty proceedings are arising as an outcome of the assessment proceedings, which is still being debated upon. If the issue is debatable, penalty proceedings cannot lie. - HC