No Section 271(1)(c) penalty if debatable issue is involved: ITAT Pune

DCIT Vs Vinod Ramchandra Jadhav (ITAT Pune) 1. Facts of the Case Vinod Ramchandra Jadhav, an individual assessee, filed his return of income for A.Y. 2010-11 under section 139(1) declaring an income of ₹77,29,880. Pursuant to a search conducted on 31.10.2010 under section 132 in the Sava Group, he was also covered and subsequently filed returns under section 153A for A.Y. 2007-08 to 2012-13. He also approached the Income Tax Settlement Commission (ITSC) under section 245C(1) offering additional income for settlement across these years. However, the ITSC, while considering his application, ma...