Section 271(1)(c) penalty not imposable for Erroneous double provision for interest

Gujarat State Electricity Corporation Ltd. Vs DCIT (ITAT Ahmedabad) During the course of assessment, the Assessing Officer has noticed that assessee has accounted interest expenses twice of Rs. 11.90 crores, therefore, the same was disallowed and also levied penalty of Rs. 1,46,48,271/- u/s. 271(1)(c) of the act on the combined amount of disallowance u/s. 14A and disallowance of interest. After perusal of the material on record, it is undisputed fact that aforesaid expenditure was twicely reflected in the annual account of the year under consideration and during the course of assessment and a...