Penalty u/s 271(1)(c) on highly debatable issue is unsustainable

A2Z Maintenance & Engineering Services Limited Vs DCIT (ITAT Delhi) ITAT Delhi held that imposition of penalty under section 271(1)(c) of the Income Tax Act on a highly debatable issue is unsustainable in law. Facts- The search and seizure operation u/s. 132 of the Act was conducted on the premises of the group cases including the assessee. The assessment was consequently carried out u/s. 153A of the Act. During the course of search operation, a disclosure of Rs.65 lakh was made under S. 132(4) of the Act. The aforesaid disclosure was included the Return of Income (ROI) filed in S. 153A pr...