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ITAT dismissed Revenue's appeal against CIT(A)'s order canceling penalty under s.271(1)(c). Assessee's claim for Mine Reclamation Expenses, though disallowed, was based on bonafide belief of allowability under s.37(1) per Mineral Conservation Rules. AO erroneously concluded absence of explanation despite documented submissions. Assessee disclosed primary facts and demonstrated reasonable cause under s.273B. Additionally, penalty notice under s.274 cited furnishing inaccurate particulars, while final order penalized for concealment of income, rendering penalty legally unsustainable due to charge inconsistency. ITAT upheld that no penalty was warranted given disclosed facts and reasonable cause defense.
ITAT dismissed Revenue's appeal against CIT(A)'s order canceling penalty under s.271(1)(c). Assessee's claim for Mine Reclamation Expenses, though disallowed, was based on bonafide belief of allowability under s.37(1) per Mineral Conservation Rules. AO erroneously concluded absence of explanation despite documented submissions. Assessee disclosed primary facts and demonstrated reasonable cause under s.273B. Additionally, penalty notice under s.274 cited furnishing inaccurate particulars, while final order penalized for concealment of income, rendering penalty legally unsustainable due to charge inconsistency. ITAT upheld that no penalty was warranted given disclosed facts and reasonable cause defense.
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