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2014 (12) TMI 1294
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....hakkar & Rajesh P. Shah O R D E R Per D. Karunakara Rao, AM These are three appeals by the Revenue filed against the order of the CIT(A)-32, Mumbai and they pertain to assessment years 2004-05, 2005-06 and 2006-07 in connection with penalty levied under section 271(1)(c). 2. At the outset the learned counsel for the assessee mentioned that the assessee received certain receipts f....
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....he impugned order is relevant here. Further the learned counsel for the assessee mentioned that mere change of head of income do not attract concealment penalty and for this proposition the counsel relied upon the jurisdictional High Court judgement in the case of CIT vs. Bennett Coleman & Co. Ltd. 87 DTR 0368. 4. The learned D.R. relied upon the penalty order passed by the AO. 5. After hear....
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....ns of business' and the claim of the assessee was consistently accepted by the Revenue. Assessee offered the same for these years also but the AO changed the head of income only in view of the subsequent judgement in the case of Shambhu Investment (P) Ltd. (supra). Therefore, there is nothing malafide from assessee's side. The AO has not information to demonstration that the claim of the assessee ....