Penalty for Unoffered Income from Web Hosting Services Deemed Unsustainable Due to Debatable Royalty Classification u/s 271(1)(c).

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....Penalty u/s 271(1)(c) - debatable issue arises - partial income not offered to tax - revenue from web hosting services - income in the nature of royalty or not - since the matter is debatable and still to attain the finality, levy of penalty is not sustainable - AT....