Penalty cannot be imposed merely because assessee had made a new claim

PCIT Vs Taneja Developers and Infrastructure Ltd. (Delhi High Court) Tribunal was required to consider, was: whether penalty could be imposed on the assessee only because it had made a new claim [in line with the change in its accounting policy] in its fresh return? Admittedly, [and there is no dispute about it] AS-7 permitted the assessee to make the new claim qua the aforementioned expenses, on an accrual basis, in the relevant assessment year 2007-2008. However, the assessee had, in its original return, filed for the said assessment year, i.e., 2007-2008, claimed deduction of a portion of t...