Penalty u/s 271(1)(c) Not Imposed Due to Lack of Tax Benefit Incentive from Disallowed Expense Claims.

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....Penalty u/s 271(1)(c) - Disallowance of claim of various expenses – The assessee has huge accumulated losses and depreciation which further strengthen the view that there was no incentive for assessee to make such claims for the benefit of tax - no penalty - AT....