TMI Blog2011 (3) TMI 46X X X X Extracts X X X X X X X X Extracts X X X X ..... ppeal by the assessee arises out of the order passed by the CIT(A) on 20.01.2009 confirming the penalty of Rs.37,32,777 imposed by the AO u/s.271(1)(c) of the Act in relation to assessment year 1997-98. 2. Shorn off unnecessary details it is an admitted position from both the sides that the penalty has been finally upheld qua the addition of Rs.1,04,76,050 towards income from Spectru ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f brokerage Rs.10,79,221/- and legal fees Rs.2,00,000/-?" 3. It is, therefore, abundantly clear that the additions in respect of which penalty was confirmed have been accepted by the Hon'ble Bombay High Court leading to substantial question of law. When the High Court admits substantial question of law on an addition, it becomes apparent that the addition is certainly debatable. In such ci ..... X X X X Extracts X X X X X X X X Extracts X X X X
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