No section 271(1)(c) penalty when Sustainability of Addition is debatable

Manjulata Sahoo Vs PCIT (ITAT Cuttack)

It was the submission that against the order of the Tribunal, the assessee has filed appeal before the Hon’ble Jurisdictional High court of Orissa and the Hon’ble Jurisdictional High Court of Orissa was pleased to admit the appeal of the assessee in ITA No.8 of 2021 vide order dated 30.1.2023. It was the submission that as the appeal has been admitted on substantial question of law, then sustainability of the addition itself become debatable and consequently, the penalty u/s.271(1)(

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