Interest Expenditure Disallowance: Findings May Justify Under Sec 271(1)(c), But Insufficient for Penalty Imposition Alone.

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....Penalty u/s 271(1)(c) - disallowance of interest expenditure - The findings of the AO may be sufficient to make disallowance in quantum on the theory of preponderance of probabilities but it is not sufficient to fasten and saddle the assessee with penalty provisions as are enshrined u/s. 271(1)(c)....