No Penalty Imposed u/s 271(1)(c) Due to Doubt on Depreciation Claim for BOT Road Construction.

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....Penalty u/s 271(1)(c) - assessee claimed depreciation u/s 32 on road constructed on Build-Operate-Transfer basis which was denied - the Revenue had itself accepted that there was a doubt and that is why the clarification of 2014 was issued. Had it been so cut and dried there was no occasion for the Board to have issued the clarification and infact, this is precisely what weighed with CIT(A) and ITAT - no penalty....