Mere fact that addition has been made or confirmed does not per se lead to imposition of penalty

Advocate Akhilesh Kumar Sah

Giesecke and Devrient [I] Pvt. Ltd Vs. DCIT (ITAT  Delhi)

A issue being a debatable issue at the point of time when the assessee filed its return of income penalty levied under section 271(1)(c) on that count cannot be sustained, mere fact that the addition has been made or confirmed does not per se lead to imposition of penalty

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