2020 (7) TMI 210

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....ross Objector submits that the Assessing Officer failed to appreciate that the Appellants claim for business expenses was purely a legal claim, and no penalty should lie even if the claim is found unsustainable in law. 2. The Assessing Officer erred in law in disregarding the decision of the Hon'ble Supreme Court in the case of Reliance Petroproducts Pvt. Ltd. (322 ITR 158). 3. Having regard to the facts and circumstances of the case, the Assessing Officer has erred in levying penalty under section 271(1)(c) of Rs. 98,71,468/- in respect of a bonafide claim of expenses. 4. The Assessing Officer erred in levying penalty for concealment of particulars of income/ furnishing inaccurate particulars of income in a case where two views w....

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....tion 274 specifies the limb for which penalty has been initiated. 4. Subsequently, Ld.CIT(A)-3 passed order dated 20/02/2018 in appeal filed by assessee challenging additions made by Ld.AO in order passed under section 143(3) of the Act, business expenses disallowed amounting to Rs. 3,04,25,242/- was confirmed, interest expenditure added under section 14A read with Rule 8D(2)(ii) of Rules was deleted and disallowance under section 14A read with Rule 8D(2)(iii) of the Act was partly allowed. Ld.AO in penalty proceedings levied penalty amounting to Rs. 98,71,468/- under section 271(1)(c) of the Act, on disallowances of business expenses for concealing particulars of income by way of filing inaccurate particulars of income. 5. Aggrieved by ....