No Penalty on Capital Gains from JDA: ITAT Says Debatable Issue Cannot Trigger Concealment Penalty

Pramod Reddy Tekula Vs DCIT (ITAT Hyderabad) No Penalty on Capital Gains from JDA: ITAT Says Debatable Issue Cannot Trigger Concealment Penalty The Hyderabad ITAT deleted the penalty levied under section 271(1)(c) on capital gains arising from a development agreement-cum-GPA, holding that the issue of taxability of capital gains in such transactions was highly debatable during the relevant period. The Tribunal observed that merely because the quantum addition was ultimately sustained does not automatically mean that the assessee had concealed income or furnished inaccurate particulars. The ass...