Section 271(1)(c) penalty cannot be imposed merely for incorrect income head treatment

D. C. Polyester Limited Vs DCIT (ITAT Mumbai) Introduction: D.C. Polyester Limited recently secured a noteworthy victory in its appeal against the imposition of a penalty under Section 271(1)(c) of the Income Tax Act. The Income Tax Appellate Tribunal (ITAT) Mumbai, in its order dated August 25, 2023, emphasized that penalties cannot be imposed solely on the grounds of wrong treatment to the head of income. Detailed Subheading-Wise Analysis: 1. Background of the Appeal: The appeal by D.C. Polyester Limited challenges the order of Ld. CIT (A)-54, Mumbai, dated November 24, 2022, concerning the ...