2018 (8) TMI 1893

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....resent penalty appeal has been filed by revenue against order dated 28/10/16 passed by Ld. CIT (A)-7 on following grounds of appeal:  "1. On the facts and under the circumstances of the case, the Ld. CIT(A) has erred in law in deleting the penalty of Rs. 5,53,00,980/- u/s 271(1)(c). Since the addition made u/s 14A of the Act read with rule 8D(iii) of Rs. 16,26,97,795/- was also sustained b....

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....ii). 4. Penalty proceedings under section 271(1)(c) of the Act was initiated for furnishing inaccurate particulars of income. Ld.AO passed penalty order by living hundred percent penalty on tax on the said disallowance under section 14 A. 5. Aggrieved by the order of Ld.AO, assessee preferred appeal before Ld.CIT(A). Ld.CIT(A) observed that assessee had filed all requisite details and there wa....

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.... error on behalf of assessee re- furnishing of inaccurate particulars or concealment of any material facts. He submitted that assessee had furnished all relevant facts and explanation regarding the claim during the assessment proceedings. It was submitted by Ld. AR that disallowance under section 14 A has always been debatable and contentious. He placed reliance upon the decision of Hon'ble Delhi ....