2015 (9) TMI 318

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....i for the Respondent ORDER Office objections waived. 2. In this appeal by the Revenue for assessment year 2003-04, following question of law has been proposed for our consideration. "Whether, on the facts and in the circumstances of the case and in law, the Tribunal was correct in holding that penalty under Section 271(1)(c) of the Act is not leviable when parameters laid in Expl....

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.... the meaning of Section 2(47) of the Act. The respondent - assessee accepted the aforesaid position. However, the assessing officer levied penalty under Section 271(1)(c) of the Act. In appeal, the Commissioner of Income Tax (A) upheld the penalty. 4. On further appeal, the Tribunal held that the respondent-assessee having made complete disclosure in the return of income, the fact that during t....