https://www.taxtmi.com/caselaws?id=447126 ITAT Rajkot held that penalty under section 271(1)(c) was not leviable where foreign company returned income under section 44BBB but AO assessed it as FTS under section 115A. The tribunal found no concealment or inaccurate particulars, noting the assessee was guided by consultants and uncertainty existed regarding correct classification. The dispute involved only interpretation of income nature, not facts or figures. CIT(A)'s deletion of penalty was upheld, following Reliance Petroproducts precedent that mere change of opinion on income classification doesn't attract penalty. en-us Fri, 15 Dec 2023 00:00:00 +0530 Tue, 19 Dec 2023 09:02:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=447126 ITAT Rajkot held that penalty under section 271(1)(c) was not leviable where foreign company returned income under section 44BBB but AO assessed it as FTS under section 115A. The tribunal found no concealment or inaccurate particulars, noting the assessee was guided by consultants and uncertainty existed regarding correct classification. The dispute involved only interpretation of income nature, not facts or figures. CIT(A)'s deletion of penalty was upheld, following Reliance Petroproducts precedent that mere change of opinion on income classification doesn't attract penalty. Case-Laws Income Tax Fri, 15 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=447126