High Court's appeal admission on substantial law questions supports assessee's position; Section 271C penalty not applicable.

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....Penalty u/s 271C -LTA - Mere admission of the appeal by the High Court on the substantial questions of law as have been quoted above, would make it apparent that the additions made were debatable. The Tribunal has thus rightly held that the admission of substantial questions of law by the High Court leads credence to the bona fide of the assessee and therefore, the penalty is not exigible u/s 271(1)(c) - AT....