Section 271(1)(c) Penalty Deleted as Additions Based Only on Differing Interpretation

Cane Deveopment Council Rohana Kalan Vs ITO (ITAT Delhi)

The appeals concern penalties imposed under Section 271(1)(c) of the Income Tax Act for Assessment Years 2010–11 and 2011–12. Four appeals filed by two assessees were heard together due to similarity in facts, with one matter treated as the lead case. The assessee challenged the penalty of ₹10,30,000 on grounds including invalid notice, lack of jurisdiction, absence of proper hearing, and incorrect appreciation of facts. It argued that mere disallowance of claims or expenses does not attr

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