Section 271(1)(c) penalty not leviable merely for non challenge to disallowance in Quantum Appeal

DCIT Vs Maharashtra State Power Generation Co. Ltd. (ITAT Mumbai)

When the assessee had came forth with the full disclosure of all the particulars in respect of its aforesaid claim of expense, which as observed by us hereinabove had not been proved to be incorrect by the lower authorities, therefore, merely for the reason that the addition/disallowance on the said count had not been assailed by the assessee in its quantum appeal before the Tribunal would not justify imposition of penalty under Sec. 271(1)(c) on the assessee on the said standalone

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