Penalty u/s 271(1)(c) Cannot Survive When Quantum Itself Is Remanded

Sachin Mahasukhlal Shah Vs DCIT (ITAT Ahmedabad) Penalty u/s 271(1)(c) Cannot Survive When Quantum Itself Is Remanded—Penalty Proceedings Restored to AO for Fresh Decision  Both appeals relate to penalty imposed u/s 271(1)(c) arising from the same quantum addition in AY 2015-16. In each case, the assessee had claimed deduction of ₹38,15,160 as interest expenditure, which the AO disallowed for lack of nexus with plot-rent income. The AO thereafter levied penalty of ₹32,02,179 in the case of Sachin Mahasukhlal Shah and ₹13,13,232 in the case of Rupa Sachin Shah. Before the Tribunal, it ...