2014 (4) TMI 1245

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....present tax appeal arising from the order of the Income Tax Appellate Tribunal('the Tribunal" for short) dated 23.8.2013 : "(1) Whether in law and on the facts and circumstances of the case, the ITAT was justified in deleting the penalty levied under section 271(1)(c) amounting to Rs. 19,47,164/­ without considering the fact that the assessee consciously made the claim of undue deduction und....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Secretary Department of Scientific and Industrial Research, Ministry of Science & Technology, the two letters had been furnished by the assessee before the Assessing Officer issued by the said department. On the ground that the letters were not in prescribed proforma as was the requirement of law, the claim was disallowed and penalty proceedings had been initiated by the AO under section 271(1)(c)....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....d with the findings of the CIT(Appeals) on the ground that it would have been ideal if the certificate issued by the Ministry of Science and Technology would have been furnished. However, on the expenditures made by the assessee for the purpose of Scientific Research and Development, no doubt was raised at any point of time by the Revenue. Tribunal was of the opinion that on a bona fide belief, wh....