Penalty imposed u/s 271(1)(c) cannot survive if issue is debatable & admitted by HC

Without going into much deliberation and merits of the case, now question arises since the substantial question of law “whether on the facts in the circumstances of the case and in law, the Tribunal was justified in holding that the appellant was not entitled to claim the loss of Rs.6.34 crore arising on conversion of UTI US 64 units in to 6.75% Tax Free Bonds of UTI?” has been admitted by the Hon’ble jurisdictional High Court, vide order dated 19^th September, 2014, now question arises whether penalty u/s 271(1)(c) of the Act survive

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