Debatable Issues No Basis for Penalty Under Section 271(1)(c): ITAT Mumbai

DCIT Vs New India Assurance Co. Ltd. (ITAT Mumbai) Summary: The case concerns an appeal by the Revenue against the order of the Commissioner of Income Tax (Appeals) [CIT(A)]/National Faceless Appeal Centre (NFAC), Delhi, dated 21.10.2023, which deleted a penalty imposed under Section 271(1)(c) of the Income Tax Act, 1961, for Assessment Year (AY) 2004–05 in the case of New India Assurance Co. Ltd. The Revenue’s primary contention was that the CIT(A) erred in deleting the penalty even though the Income Tax Appellate Tribunal (ITAT) had confirmed quantum additions made by the Assessing Offic...