No Penalty despite unsustainable/ non-debatable claim by Assessee if duly disclosed

No Penalty despite unsustainable/ non-debatable claim by the Assessee if duly disclosed by the Assessee Issue – Whether in the facts and in the circumstances of the case and in law, the ITAT was right in holding that the wrong claim made by the assessee is not filing of inaccurate particulars, ignoring the fact that the assessee has knowingly claimed the setting off of loss against other source of income under the same head arising out of sell of units US-64 to be exempted u/s. 10(33) as income includes loss which has been accepted by the assessee before the ITAT during the course of qua...