https://www.taxtmi.com/caselaws?id=775040 ITAT Ahmedabad deleted penalty proceedings u/s. 271(1)(c) on multiple grounds. Regarding disallowance of selling and distributing expenses, the tribunal held the issue was highly debatable with existing contrary views, making penalty non-imposable. For disallowance u/s. 14A, penalty was deleted due to lack of evidence of inaccurate particulars. On repairing expenses, the tribunal ruled that mere disallowance of claimed expenditure doesn't attract penalty when assessee furnished complete details in return, as acceptance remains with authorities. For penalty u/s. 115JB on doubtful debts provisions, the tribunal followed Gujarat HC precedent in Citi Tiles Ltd. The tribunal rejected assessee's challenge regarding AO's satisfaction recording, finding proper invocation during assessment proceedings. However, penalty on book profit addition u/s. 115JB for partnership remuneration was deleted, following Calcutta HC ruling in Ankit Metal & Power Ltd that non-income items under section 2(24) cannot be taxed under MAT provisions. en-us Tue, 15 Jul 2025 00:00:00 +0530 Fri, 18 Jul 2025 08:22:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=775040 ITAT Ahmedabad deleted penalty proceedings u/s. 271(1)(c) on multiple grounds. Regarding disallowance of selling and distributing expenses, the tribunal held the issue was highly debatable with existing contrary views, making penalty non-imposable. For disallowance u/s. 14A, penalty was deleted due to lack of evidence of inaccurate particulars. On repairing expenses, the tribunal ruled that mere disallowance of claimed expenditure doesn't attract penalty when assessee furnished complete details in return, as acceptance remains with authorities. For penalty u/s. 115JB on doubtful debts provisions, the tribunal followed Gujarat HC precedent in Citi Tiles Ltd. The tribunal rejected assessee's challenge regarding AO's satisfaction recording, finding proper invocation during assessment proceedings. However, penalty on book profit addition u/s. 115JB for partnership remuneration was deleted, following Calcutta HC ruling in Ankit Metal & Power Ltd that non-income items under section 2(24) cannot be taxed under MAT provisions. Case-Laws Income Tax Tue, 15 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=775040