No penalty on taxation of ESOP when only CBDT Circular was there on its taxation

No penalty can be levied under s 271(1)(c) when there was only the CBDT Circular on the taxation of ESOP shares and where the assessee offered certain income in a particular year and paid taxes bona fidely and the AO taxed the same in another year.

ACIT Vs Vijay Kumar Jindal (ITAT Delhi)- There was no law on taxation of Esop shares for A.Y. 1999-2000. Only CBDT Circular no. 710 was there clause (iv) of the same provided that where shares have been offered only to the employees, the v

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