TaxTMI 
TaxTMI 
2012 (5) TMI 673
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.... VP : The only ground raised in this appeal by the assessee is against the levy of penalty of ₹ 18,79,303/- imposed under Section 271(1)(c) of the Income-tax Act, 1961. 2. We have heard both the parties and have perused the material placed before us. In this case, originally, the ITAT had quashed the penalty imposed under Section 271(1)(c) on the technical ground that specific satisfactio....
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....d CIT(A), vide his order dated 8.2.2011, deleted the addition of ₹ 3,82,636/-. Therefore, the penalty in respect of the addition which has been deleted cannot survive. Now, the only dispute which remains is whether the penalty under Section 271(1)(c) can be levied in respect of reduction in the deduction claimed by the assessee under Section 80HHC. In our opinion, this issue is squarely cove....
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....see. In the case of the assessee, her claim for deduction under Section 80HHC was not found to be not sustainable in law. On the other hand, the Assessing Officer himself has allowed the deduction under Section 80HHC but, he merely recomputed the quantum of the deduction claimed under Section 80HHC. Merely because the Assessing Officer has changed the quantum of the deduction permissible under Sec....