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    <title>2021 (9) TMI 1163 - ITAT DELHI</title>
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    <description>The Tribunal allowed the appeal, directing the Assessing Officer to delete the penalty imposed under Section 271(1)(c) of the Income-tax Act, 1961. The Tribunal found that the penalty proceedings were initiated based on incorrect facts, which were nullified by the relief granted in quantum proceedings by the ITAT. The collaboration and supplemental agreements were misinterpreted, and the CIT(A) failed to consider detailed submissions, leading to an unreasonable decision. The Tribunal concluded that the penalty was unsustainable and ordered its deletion, allowing the appeal filed by the assessee.</description>
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      <description>The Tribunal allowed the appeal, directing the Assessing Officer to delete the penalty imposed under Section 271(1)(c) of the Income-tax Act, 1961. The Tribunal found that the penalty proceedings were initiated based on incorrect facts, which were nullified by the relief granted in quantum proceedings by the ITAT. The collaboration and supplemental agreements were misinterpreted, and the CIT(A) failed to consider detailed submissions, leading to an unreasonable decision. The Tribunal concluded that the penalty was unsustainable and ordered its deletion, allowing the appeal filed by the assessee.</description>
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