Section 271(1)(c) Penalty not sustainable for bonafide & disclosed deduction claim: Bombay HC

Carona Limited Vs DCIT (Bombay High Court) AO passed 143(3) order by adding back inter-alia the amount of ad-hoc bonus of Rs.22,21,123/- which was not offered by the Assessee for taxation,  recording  a finding that the case was fit for attracting the provisions of Sec 271(1)(c  for imposition of penalty on account of explanation of the Assessee in respect of the bonus amount not being found bonafide. The penalty was later levied.   On appeal, CIT(A), set aside the penalty by allowing,  inter-alia, holing   that the explanation offered by the Assessee for not offering ad-hoc bonus am...