2018 (1) TMI 1744

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....e : Sm t. Chandrakanta ORDER PER DR. B.R.R. KUMAR, A.M. The present appeal has been filed by the assessee against the order of the Ld. CIT(A)-2 Ludhiana dt. 13/07/2017. 2. The only effective ground of appeal is as under: 1. That the Ld. CIT(A)-2 has erred in confirming the levy of penalty of Rs. 90,404/- u/s 271(1)(c) on the disallowance under section 40(a)(ia) of Rs. 2,92,569....

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....the Ld. AR submitted that the disallowance not added in the return due to oversight and it was a bonafide mistake. He relied on the judgment of Hon'ble Supreme Court in the case of CIT Vs. Reliance Petro products Pvt. Ltd. (322 ITR 158) dated 17/03/2010 held that when the assessee has made a claim under the bonafide belief and disallowance of such claim would not attract levy of penalty. 6.....