ITAT Bangalore: Mere Wrong Claim u/s 54 Does Not Attract Penalty u/s 271(1)(c)

Smt. Suma Narsimha Rao Vs DCIT (ITAT Bangalore) ITAT Bangalore: Mere Wrong Claim u/s 54 Does Not Attract Penalty u/s 271(1)(c) The Bangalore ITAT deleted penalty levied under Section 271(1)(c) where the assessee, a non-resident, had claimed deduction under Section 54 on reinvestment of capital gains. Although the claim was disallowed because the sale deed was executed beyond the prescribed time, the Tribunal held that substantial investment was made within the stipulated period, and all facts were fully disclosed in the return. The Tribunal emphasized that the issue was debatable and arguable,...