2020 (10) TMI 296

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....e J.B. Pardiwala) 1. This tax appeal under Section 260A of the Income Tax Act, 1961 is at the instance of the revenue and is directed against the order passed by the Income Tax Appellate Tribunal, "B" Bench, Ahmedabad dated 26.07.2019 in the ITA No.627/Ahd/2018 for the A.Y. 2006-07. The Revenue has proposed the following question of law for the consideration of this Court; "Whether the Appellat....

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....i has not included the transactions with assessee in his statement at all. 7. At this stage, we bear in mind that incidence of penalty under s. 271(1)(c) of the Act is not automatic and should not be imposed merely because it is lawful to do. Considering the smallness of the amount involved, we consider it expedient to give benefit of doubt to the assessee owing to mitigating circumstances viz; ....