Rejection of claim does not raise inference of a mala fide attempt to evade tax

The assessee filed a return cf income claiming deductions under section 18(1)(b) of the Act. The deductions were disallowed. The Assessing officer, also directed initiation cf penalty proceedings, under Sections 271(1)(c) cf the Act. The Assessing Officer’s order was affirmed up to the Income Tax Appellate Tribunal. The Assessing officer, thereafter,passed an order imposing penalty.

The controversy, in the present case, is fully covered against the assessee by a judgment of the Delhi High Court in Commissioner of Income Tax versus Zoom Communi

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