Assessee not penalized u/s 271(1)(c) for estimated expense allocations; lack of dishonesty in income reporting.

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....Levy of penalty u/s 271(1)(c) - deduction claimed u/s 80IA - there being no factual basis for establishing that the expenses needed to be allocated and the expenses so allocated being only estimated, the assesses claim of not allocating such expenses to the eligible units cannot be said to have been proved to be not bonafide. The assessee cannot therefore, in such circumstances be charged with having concealed/furnished any inaccurate particulars of income so as to attract levy of penalty u/s 271(1)(c) of the Act. - AT....