No Penalty for Higher Deduction Claim u/s 36(1)(viia) Due to Bona Fide Auditor Opinion.

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....Penalty u/s.271(1)(c) - claimed higher deduction u/s.36(1)(viia) based on opinion of the Central Statutory Auditors - latter on based on different view canvassed against the other banks, reduced the claim of deduction to the actual amount of provision created in the books of account by revised return - it is a clear cut case of bona fide opinion - no penalty....