No Penalty u/s 271(1)(c) on debatable issues, estimations, change in accounting method / income Head & preponment of taxable income

Brief of the Case Mumbai ITAT held In the case of M/s Parinee Developers Pvt. Ltd. vs. ACIT that the concealment penalty levied by the CIT (A) in this case is on the issues which are not free from debate. In our opinion, the assessee would have got relief in most of issues relating to additions based on the estimations, change of method of accounting, pre-ponement of taxable income to AY 2009-2010 etc. Taxation of interest receipt with or without netting is under the head “profit and gains from business or profession” or “income from other sources” is also a debatable issue. Therefore,...