Penalty cannot be imposed for mere non acceptance of claim made by Assessee

Brief- Merely because the assessee had claimed the expenditure, where claim was not accepted or was not acceptable to the revenue, that by itself would not, attract the penalty under Section 271(1)(c). Brief Facts of the Assessee: The Assessee has claimed the exemption under section 10A of the Act Income Tax Act, 1961 (“The Act”). During assessment, the Assessing officer had excluded the income on account of foreign exchange fluctuation for computing eligible income for deduction u/s.10A. The Assessee had claimed the expenditure of one unit against another unit which was not eligible for d...