2018 (8) TMI 1783

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....URABLE MR.JUSTICE AKIL KURESHI) 1. This appeal is filed by the Revenue challenging judgement of the Income Tax Appellate Tribunal dated 19.03.2018 raising following question for our consideration: "Whether on the facts and in the circumstances of the case and in law, the Appellate Tribunal is justified in holding that the penalty of Rs. 101,24,35,719/- levied u/s. 271(1)(c) of the Act ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Act. The Assessing Officer rejected, the claim and also instituted penalty proceedings. By the order dated 12.03.2015, he imposed penalty of Rs. 101.24 cores being 1/3rd of the maximum imposable penalty. The assessee carried the matter in appeal. CIT(A) deleted the penalty on the ground that assessee has succeeded before the Gujarat High Court in quantum additions. Same was the view expressed by t....