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    <title>2014 (11) TMI 374 - ITAT DELHI</title>
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    <description>The Tribunal upheld the CIT(A)&#039;s decision to delete the penalty of Rs. 1,53,65,958/- imposed under Section 271(1)(c) of the Income Tax Act, 1961. The penalty was canceled as it was based on a retrospective amendment that was not foreseeable by the assessee at the time of filing the return. The Tribunal emphasized that the assessee had made a bona fide claim supported by legal opinions and judicial pronouncements existing at the time of filing. The revenue&#039;s appeal was dismissed, confirming that the penalty was not justified in this case.</description>
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    <pubDate>Fri, 22 Aug 2014 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=253057</link>
      <description>The Tribunal upheld the CIT(A)&#039;s decision to delete the penalty of Rs. 1,53,65,958/- imposed under Section 271(1)(c) of the Income Tax Act, 1961. The penalty was canceled as it was based on a retrospective amendment that was not foreseeable by the assessee at the time of filing the return. The Tribunal emphasized that the assessee had made a bona fide claim supported by legal opinions and judicial pronouncements existing at the time of filing. The revenue&#039;s appeal was dismissed, confirming that the penalty was not justified in this case.</description>
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      <pubDate>Fri, 22 Aug 2014 00:00:00 +0530</pubDate>
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