No penalty for preferring a claim which is unacceptable to Revenue

HCL Technologies Ltd. Vs DCIT (ITAT Delhi) Levy of penalty in this case is unsustainable because mere preferring a claim which is unacceptable to the Revenue does not ipso facto lead to levy of penalty. Here in this case, Form No. 56F duly signed by the Chartered Accountant justifies the plea of bona fide belief on the part of the assessee. It is not the allegation against the assessee that any material fact relating to the income had to be unearthed with any efforts of the Revenue. It is only on the basis of the material furnished by the assessee, claim of the assessee for benefit u/s. 10A of...