Mere CA’s opinion cannot absolve assessee from penalty u/s 271(1)(c)

Just because a claim is supported by a CA’s opinion, it cannot absolve assessee from penalty u/s 271(1)(c) A plain look at the legal opinion obtained from Vakharia & Associates, which learned Accountant Member has reproduced in his order, shows that all that this tax consultant has opined is that the CBDT circular dated 23rd January 2001 ceases to hold good in law in view of Hon’ble Bombay High Court’s judgment in the case of Bhor Industries Ltd (supra). There cannot indeed be any quarrel with this proposition, but then this expert advice does not deal with the provisions of Sectio...