https://www.taxtmi.com/caselaws?id=437150 Delhi HC upheld deletion of penalty u/s 271(1)(c) regarding foreign currency fluctuation losses on machinery cost. Assessee initially claimed losses as deductible expenditure but accepted during scrutiny that losses must be capitalized under Section 43A and claimed depreciation on increased asset cost instead. Court found no penalty warranted as assessee had unabsorbed losses, gained no advantage from incorrect claim, and made course correction before assessment order. Action constituted unsustainable legal claim rather than concealment of income. en-us Wed, 22 Mar 2023 00:00:00 +0530 Sat, 10 May 2025 11:38:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=437150 Delhi HC upheld deletion of penalty u/s 271(1)(c) regarding foreign currency fluctuation losses on machinery cost. Assessee initially claimed losses as deductible expenditure but accepted during scrutiny that losses must be capitalized under Section 43A and claimed depreciation on increased asset cost instead. Court found no penalty warranted as assessee had unabsorbed losses, gained no advantage from incorrect claim, and made course correction before assessment order. Action constituted unsustainable legal claim rather than concealment of income. Case-Laws Income Tax Wed, 22 Mar 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=437150