Penalty Deleted as Issue Becomes Debatable – HC Admission of Quantum Appeal Saves Assessee

DCIT Vs Palmer Investment Group Ltd (ITAT Bangalore) Penalty Deleted as Issue Becomes Debatable – HC Admission of Quantum Appeal Saves Assessee The ITAT Bangalore upheld the deletion of penalty under Section 271(1)(c), holding that once the High Court admits the quantum appeal on substantial questions of law, the issue becomes debatable and penalty cannot survive. The case involved a non-resident company where substantial transfer pricing adjustment (₹262 crores) was made on sale of shares, which was upheld by the Tribunal. The assessee challenged the quantum before the Karnataka High ...