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    <title>2011 (4) TMI 939 - ITAT DELHI</title>
    <link>https://www.taxtmi.com/caselaws?id=210356</link>
    <description>The Tribunal held that no penalty under section 271(1)(c) should be imposed on the appellant for the disallowance of interest payable claim. The Commissioner of Income-tax (Appeals) had deleted the addition made by the Assessing Officer, emphasizing that the interest amount was a liability based on a court order. However, the Tribunal disagreed with the Commissioner, reinstating the Assessing Officer&#039;s addition. The Tribunal found that the appellant&#039;s varying positions in different assessment years were justified by external events, indicating no mala fide intent to evade taxes. Consequently, the penalty was canceled, and the appellant&#039;s appeal was allowed.</description>
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    <pubDate>Fri, 30 Apr 2010 00:00:00 +0530</pubDate>
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      <title>2011 (4) TMI 939 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=210356</link>
      <description>The Tribunal held that no penalty under section 271(1)(c) should be imposed on the appellant for the disallowance of interest payable claim. The Commissioner of Income-tax (Appeals) had deleted the addition made by the Assessing Officer, emphasizing that the interest amount was a liability based on a court order. However, the Tribunal disagreed with the Commissioner, reinstating the Assessing Officer&#039;s addition. The Tribunal found that the appellant&#039;s varying positions in different assessment years were justified by external events, indicating no mala fide intent to evade taxes. Consequently, the penalty was canceled, and the appellant&#039;s appeal was allowed.</description>
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