2021 (10) TMI 783

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....rma, CIT-D.R. Assessee by: Shri M.K. Patel, A.R. ORDER PER : AMARJIT SINGH, ACCOUNTANT MEMBER:- This assessee's appeal for A.Y. 2007-08, arises from order of the CIT(A)-1, Vadodara dated 19-05-2017, in proceedings under section 271(1)(c) of the Income Tax Act, 1961; in short "the Act". 2. The solitary ground of appeal of the assessee is directed against the decision of ld. CIT(A) in....

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....re us, the ld. counsel has filed paper book comprising detail and copy of document filed before the Assessing Officer and ld. CIT(A). The ld. counsel has submitted that assessee had accounted the provision for interest twice by mistake and on realizing the mistake rectification entries were passed in the subsequent year and same was shown as income. The ld. counsel has also enclosed the copies of ....

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....er authorities and contended that assessee is a public sector undertaking and its accounts are added. 5. Heard both the sides and perused the material on record. During the course of assessment, the Assessing Officer has noticed that assessee has accounted interest expenses twice of Rs. 11.90 crores, therefore, the same was disallowed and also levied penalty of Rs. 1,46,48,271/- u/s. 271(1)(c) ....

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....also gone through judicial pronouncements referred by the ld. counsel decision of 322 ITR 158 (SC) Reliance Petro-Products Pvt. Ltd. & 348 ITR 306 (SC) Price Watercoopers Pvt. Ltd. wherein it is held merely because assessee had claimed expenditure which claim was not accepted or was not acceptable to revenue that by itself would not attract penalty u/s. 271(1)(c) of the act. We have also gone thro....