Levy of penalty u/s 271(1)(c) unsustainable as matter debatable

 Atul Limited Vs DCIT (ITAT Ahmedabad)

ITAT Ahmedabad held that in an identical matter, jurisdictional High Court ruled the matter in favour of the assessee, however, later on Apex Court held otherwise. Accordingly, the issue was debatable do to which levy of penalty u/s 271(1)(

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