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ITAT set aside penalty under s271(1)(c) of Income Tax Act following deletion of quantum addition in earlier proceedings. The underlying dispute involved classification of supervision income as "Income from Other Sources" versus manufacturing income eligible for s80IB deduction. Tribunal found CIT(A)'s order arbitrary and perverse for failing to acknowledge prior ITAT ruling that eliminated the basis for penalty. Noting serious deficiencies in appellate adjudication, ITAT directed matter to Pr. CCIT Ahmedabad for administrative review. Following established principle that penalty cannot survive when its foundation ceases, penalty was deleted and appeal allowed.
ITAT set aside penalty under s271(1)(c) of Income Tax Act following deletion of quantum addition in earlier proceedings. The underlying dispute involved classification of supervision income as "Income from Other Sources" versus manufacturing income eligible for s80IB deduction. Tribunal found CIT(A)'s order arbitrary and perverse for failing to acknowledge prior ITAT ruling that eliminated the basis for penalty. Noting serious deficiencies in appellate adjudication, ITAT directed matter to Pr. CCIT Ahmedabad for administrative review. Following established principle that penalty cannot survive when its foundation ceases, penalty was deleted and appeal allowed.
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