No penalty where assessee relied on professional opinion & there is no tax impact

Relevant Extract of the Judgment

3. The question is whether the assessee is liable to penalty in view of its change of stand in respect of its return of income for the said assessment year.

4. The assessee was earlier known as Max Atotech Limited. It appears initially to have been a private limited company and was thereafter converted into a public limited company. For the assessment year 2004-2005, the assessee in its return of income sought to set off i

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