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    <title>2012 (9) TMI 558 - ITAT DELHI</title>
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    <description>Penalty under section 271(1)(c) was held unsustainable where the assessee supported its commission expenditure claim with correspondence, bank records, account payee payments and receipts, and the Revenue relied mainly on third-party statements without effective cross-examination. The Tribunal noted that the assessee&#039;s explanation was not shown to be false or mala fide, and that the underlying quantum controversy was itself debatable. On that basis, the deletion of penalty was upheld and the Revenue&#039;s appeals were dismissed.</description>
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      <title>2012 (9) TMI 558 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=216750</link>
      <description>Penalty under section 271(1)(c) was held unsustainable where the assessee supported its commission expenditure claim with correspondence, bank records, account payee payments and receipts, and the Revenue relied mainly on third-party statements without effective cross-examination. The Tribunal noted that the assessee&#039;s explanation was not shown to be false or mala fide, and that the underlying quantum controversy was itself debatable. On that basis, the deletion of penalty was upheld and the Revenue&#039;s appeals were dismissed.</description>
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      <pubDate>Fri, 07 Sep 2012 00:00:00 +0530</pubDate>
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