Dispute Between AO and CIT(A) Over Penalty Imposition u/s 271(1)(c); Disallowance Doesn't Mean Automatic Penalty.

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....AO and the CIT (A) are not on the same page for levy of penalty u/s 271 (1)(c) of the Act. Further, mere disallowance of a claim will not automatically attract the levy of penalty - AT....