Penalty not leviable when serious financial constraint prohibited assessee from discharging self-assessment tax

DCIT Vs Karanja Terminal and Logistic Pvt. Ltd (ITAT Mumbai) Facts- AO observed that the assessee had failed to pay its admitted self-assessment tax liability of INR 3,92,70,237/-. Assessee submitted that failure to discharge self-assessment tax was due to financial constraints that were primarily triggered by delay in commencement of its project. It was also submitted that its solitary source of income i.e., interest receivable from NBFC’s was accounted for on an accrual basis was not received by it. AO, vide his order passed under section 221(1) r.w.s. 140A(3), holding assessee as being in...