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2014 (7) TMI 999 - BOMBAY HIGH COURTImposition of penalty u/s 271(1)(c) – Held that:- Merely because the Assessee raised a claim which was eventually disallowed, does not mean that ingredients of clause(c) are satisfied or fulfilled so as to justify imposition of penalty - Tribunal followed the decision in Commissioner of Income Tax v/s Reliance Petro products Pvt Ltd [2010 (3) TMI 80 - SUPREME COURT] - Revenue officers must realize that just like other powers an executive power conferred in them is in the nature of a Trust - They hold office as trustees of the public at large - They deal with public revenue and public money and that cannot be wasted in such frivolous litigation – appeal dismissed with costs – Decided against Revenue.
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