Penalty u/s. 271(1)(c) not leviable in case of debatable issue: ITAT Ahmedabad

Gujarat Insecticides Ltd. Vs DCIT (ITAT Ahmedabad)

ITAT Ahmedabad held that it is settled principle of law that penalty under section 271(1)(c) cannot be levied in case of debatable issue. Accordingly, penalty order quashed and appeal allowed.

Facts- This appeal has been filed by the assessee against the order of the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi (NFAC) upholding the penalty levied by the Assessing Officer u/s. 271(1)(c) of the Income Tax Act, 1961 amounting to Rs.58,97,870/- in respect of the disallowance of a

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