2020 (12) TMI 521
X X X X Extracts X X X X
X X X X Extracts X X X X
....e CIT(A)-14, Mumbai deleting the penalty amounting to Rs. 1,66,43,021/- imposed by the Assessing Officer (AO) u/s. 271(1)(c) of the Income-tax Act, 1961 (hereinafter also called 'the Act') in relation to the assessment year 2007-08. 2. Briefly stated, the facts of the case are that the assessee sold certain land and declared long term capital gain on sale thereof. The AO opined that such ....
X X X X Extracts X X X X
X X X X Extracts X X X X
....rently from the one portrayed by the assessee, cannot in our considered opinion be a cause for imposing penalty u/s. 271(1)(c) of the Act. The Hon'ble Supreme Court in CIT Vs. Reliance Petro products 322 ITR 158 (SC) has held that no penalty should be imposed when the assessee adopts a bona fide view and has declared all the necessary particulars concerning the income in dispute. Since the vie....