https://www.taxtmi.com/caselaws?id=786613 Penalty under section 271(1)(c) of the Income-tax Act was held not leviable because the addition arose from a bona fide legal dispute over the taxability of interest, commitment fees and fees for technical services under the India-Germany DTAA. The income had been disclosed in reassessment proceedings or voluntarily offered during appellate proceedings, and there was no finding that the return contained false or inaccurate particulars. Mere rejection of the assessee's legal claim, without concealment or erroneous disclosure, was insufficient to sustain penalty. The deletion of penalty was therefore maintained in favour of the assessee. en-us Wed, 04 Feb 2026 00:00:00 +0530 Sat, 14 Feb 2026 10:35:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=786613 Penalty under section 271(1)(c) of the Income-tax Act was held not leviable because the addition arose from a bona fide legal dispute over the taxability of interest, commitment fees and fees for technical services under the India-Germany DTAA. The income had been disclosed in reassessment proceedings or voluntarily offered during appellate proceedings, and there was no finding that the return contained false or inaccurate particulars. Mere rejection of the assessee's legal claim, without concealment or erroneous disclosure, was insufficient to sustain penalty. The deletion of penalty was therefore maintained in favour of the assessee. Case-Laws Income Tax Wed, 04 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=786613