Bona Fide Mutuality Claim Bars U/s 271(1)(c) Penalty on Bank Interest

Uttaranchal Cooperative Sugar Factories Federation Limited Vs ACIT (ITAT Dehradun) Bona Fide Mutuality Belief Shields from Penalty: 271(1)(c) Deleted on Bank Interest & Tender Fee Dehradun ITAT  deleted penalties levied u/s 271(1)(c) holding that penalty cannot be imposed where income was not offered due to a bona fide belief based on the doctrine of mutuality and the issue was debatable at the relevant time. The Assessee, a Government-controlled cooperative federation, did not initially file returns on the belief that its income was exempt on principle of mutuality, a view supported by t...