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Penalty u/s 271(1)(c) Not Warranted for Capital Expenditure; Depreciation Claim Allowed as an Expense.

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....Penalty u/s 271(1)(c) - Even if ld. AO has treated the amount as capital expenditure, certainly assessee will be entitled to claim depreciation but the crux is, it is allowable expenditure. Such situation certainly does not call for a penalty u/s 271(1)(c) of the Act. - AT....