TaxTMI 
TaxTMI 
2025 (4) TMI 2129
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...., CA - Ld. ARs For the Revenue : Sh. Manpreet Singh Duggal - Ld. Sr. DR ORDER MANOJ KUMAR AGGARWAL (ACCOUNTANT MEMBER) 1. Aforesaid appeal by Revenue for Assessment Year (AY) 2014-15 arises out of an order of learned Commissioner of Income Tax (Appeals), dated 22-03-2024 in the matter of impugned penalty levied by Ld. AO u/s 271(1)(c) vide its order dated 31-01-2019. Having heard rival....
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....ated against the assessee u/s 271(1)(c) which culminated into impugned penalty of Rs. 1.65 Crores vide AO's order dated 31-01-2019 despite the claim of the assessee that it was not a case of furnishing of inaccurate particulars of income by the assessee. The impugned issue was debatable one and involved interpretation of law. Nevertheless, full details were made available on record and therefore, ....
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....the aforesaid facts, it clearly emerges that the assessee has incurred certain expenditure which were substantially disallowed by the assessee being capital in nature. The remaining expenditure was claimed under bona-fide belief that the same would be an allowable deduction u/s 37. The Ld. AO opined differently. Nevertheless, on these facts, it could not be said that the assessee furnished inaccur....