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Penalty proceedings u/s 270A - under reporting of the income - The Tribunal noted that the issue of depreciation on mining rights was debatable, supported by various judicial precedents favoring the allowance of depreciation. Considering the bona fide belief of the appellant, supported by legal precedents and the application for immunity under Section 270AA, the Tribunal upheld the CIT(A)'s decision to delete the penalty.
Penalty proceedings u/s 270A - under reporting of the income - The Tribunal noted that the issue of depreciation on mining rights was debatable, supported by various judicial precedents favoring the allowance of depreciation. Considering the bona fide belief of the appellant, supported by legal precedents and the application for immunity under Section 270AA, the Tribunal upheld the CIT(A)'s decision to delete the penalty.
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