TMI Blog2022 (8) TMI 194X X X X Extracts X X X X X X X X Extracts X X X X ..... reliance was rightly placed on the Hon'ble Supreme Court judgment in the case of CIT vs. Reliance Petro Products (P) Ltd. [ 2010 (3) TMI 80 - SUPREME COURT] . Ld. Sr. DR was unable to cite any proposition of law to the contrary as relied by Ld. CIT(A). Appeal dismissed. - ITA No. 836/Del/2020 - - - Dated:- 22-7-2022 - Dr. B.R.R. Kumar, Member (A) And Anubhav Sharma, Member (J) Revenue ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f Rs. 13,12,15,032/-. Thereafter, assessment proceedings were initiated upon the appellant company. Assessment u/s. 143(3) was completed on 27.03.2015 with the following additions/disallowances: 1. Addition on account of notional interest on share application money advanced - Rs. 13,80,08,863/- 2. Disallowance u/s. 14A - Rs. 1,40,75,583/- The aforesaid assessment order was appealed by ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... cting penalty under Section 271(1)(c) of the Act. Therefore, that being the case of the appellant, no penalty can be levied on the appellant under Sec. 271(1)(c) and hence, the grounds of appeals are upheld and the penalty is deleted. 4. Now the revenue is in appeal raising following grounds:- 1. Whether on facts and in the circumstances of the case the Ld. CIT(A) has erred in deleting t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... disallowance u/s. 14A does not fall within the ambit of being categorized as inaccurate particulars for the purpose of Section 271(1)(c) of the Act and for which reliance was rightly placed on the Hon'ble Supreme Court judgment in the case of CIT vs. Reliance Petro Products (P) Ltd. (2010) 322 ITR 158 (SC). Ld. Sr. DR was unable to cite any proposition of law to the contrary as relied by Ld. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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