https://www.taxtmi.com/caselaws?id=771118 ITAT Mumbai held that penalty under Section 271(1)(c) cannot be levied when addition is made on protective basis. The assessee's case involved interest income from foreign bank account and Standard Chartered Bank Mumbai, where reassessment proceedings were initiated based on revenue information. Since the income was already taxed in the father's hands and penalty imposed there, protective addition in assessee's hands could not sustain penalty. CIT(A) correctly deleted the penalty. For Standard Chartered Bank interest, if excluded, income would fall below taxable limit, making penalty inapplicable. Appeal decided in assessee's favor. en-us Tue, 29 Apr 2025 00:00:00 +0530 Tue, 20 May 2025 12:02:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=771118 ITAT Mumbai held that penalty under Section 271(1)(c) cannot be levied when addition is made on protective basis. The assessee's case involved interest income from foreign bank account and Standard Chartered Bank Mumbai, where reassessment proceedings were initiated based on revenue information. Since the income was already taxed in the father's hands and penalty imposed there, protective addition in assessee's hands could not sustain penalty. CIT(A) correctly deleted the penalty. For Standard Chartered Bank interest, if excluded, income would fall below taxable limit, making penalty inapplicable. Appeal decided in assessee's favor. Case-Laws Income Tax Tue, 29 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=771118