2014 (6) TMI 970

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..... d in its return of income that the amount of front end fees to be non taxable in India. The note was also annexed to the return giving the basis for which the claim was made. In these circumstances whether the Assessee's stand was justified or otherwise, surely the penalty proceedings could not have been initiated and the penalty could not have been imposed. - Decided in favour of assessee. - INC .....

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..... al after scrutinizing all the facts and considering the circumstances arrived at a conclusion that the imposition of penalty was not justified at all. The Tribunal has held and relying upon the judgment of the Honourable Supreme Court in the case of Commissioner of Income Tax v/s Reliance Petroproducts Pvt. Ltd. reported in (2010) 322 ITR 158 (SC), that any statement made or details supplied b .....

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