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    <title>2015 (12) TMI 102 - ITAT LUCKNOW</title>
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    <description>The Tribunal found that the penalty imposed under section 271(1)(c) of the Income-tax Act was unwarranted as the assessee had a reasonable belief in claiming a deduction based on a Tribunal order. The subsequent change in legal position did not amount to concealment or inaccurate particulars. The penalty was deemed unjustified, and the lower authorities&#039; orders were set aside, leading to the deletion of penalties in all assessment years. The Tribunal concluded that the Revenue wrongly imposed the penalty without considering the assessee&#039;s genuine belief, allowing the appeals and deleting the penalties.</description>
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      <link>https://www.taxtmi.com/caselaws?id=268798</link>
      <description>The Tribunal found that the penalty imposed under section 271(1)(c) of the Income-tax Act was unwarranted as the assessee had a reasonable belief in claiming a deduction based on a Tribunal order. The subsequent change in legal position did not amount to concealment or inaccurate particulars. The penalty was deemed unjustified, and the lower authorities&#039; orders were set aside, leading to the deletion of penalties in all assessment years. The Tribunal concluded that the Revenue wrongly imposed the penalty without considering the assessee&#039;s genuine belief, allowing the appeals and deleting the penalties.</description>
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      <pubDate>Fri, 11 Sep 2015 00:00:00 +0530</pubDate>
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