9911796707
TMI Blog2013 (10) TMI 1221X X X X Extracts X X X X X X X X Extracts X X X X ..... "(i) Whether, on the facts and in the circumstances of the case and in law, the Tribunal was justified in deleting the penalty levied under section 271(1)(c) in respect of disallowance made on account of curtailment of deduction under section 80-IB of the Income-tax Act, 1961 ? (ii) Whether, on the facts and in the circumstances of the case and in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e for the assessment year 199697 and upheld the deletion of penalty. The Tribunal also observed that the High Court had admitted an appeal on the question of law only in respect of the quantum proceeding for the assessment year 1996-97. In that view of the matter, the Tribunal followed its order for the assessment year 199697. The Tribunal has recorded a finding of fact that the amounts were offer ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ies was offered to tax by the assessee voluntarily. The Tribunal returns a finding of fact that these amounts were offered to tax by the assessee on its own and not after detection on the part of the Assessing Officer. Further, the Tribunal also records that similar income was assessed for tax in the assessment year 2002-03 and the Assessing Officer chose not to impose penalty upon the respondent- ..... X X X X Extracts X X X X X X X X Extracts X X X X
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