Penalty Not Automatic for Disallowed NPA Expenses u/s 271(1)(c) of Income Tax Act.

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....Penalty u/s 271(1)(c) - Revenue expenditure or not - expenses on NPA’s - merely because the assessee has claimed the expenditure, which claim was not accepted or not acceptable to the Revenue, that by itself would not attract penalty u/s. 271(1)(c)....