Penalty u/s 271(1)(C) can’t be levied in succeeding year if on similar/ identical disallowance, no penalty was levied in preceding year

Brief of the case

1. In the case of Asst Commissioner of Income Tax vs. Dhariwal Industries Ltd, Hon’ble ITAT has held that once issue on which penalty u/s 271 (1)(C)levied involves substantial question of law, then, no penalty is leviable. And no penalty can be levied in succeeding assessment year, if in proceeding assessment year AO has not levied penalty on similar/ identical disallowance.

Facts of the case

1. The ass

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