Penalty U/s. 271(1) (c) not attracted on addition U/s. 14A on debatable issue

Brief of the Case ITAT Delhi held In the case of M/s. Mohair Investment and Trading Company (P) Ltd. vs. DCIT that it is clear that the present issue, related to application of section 14A, especially in relation to shares held as trading assets, was clearly debatable and so it cannot be visited with penalty under section 271(1)(c). Further we find that the assessee has furnished all the details relating to the earning of dividend income. So it cannot be said that the assessee had concealed income or furnished inaccurate particulars of income. Hence penalty u/s 271 (1) (C) is not sustainable. ...