2018 (6) TMI 1580

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..... s in appeal against the judgment of the Income Tax Appellate Tribunal, Ahmedabad dated 27th June 2017, raising the following questions for our consideration : [A] "Whether in the facts and circumstances of the case, the Tribunal has erred in law and on facts in deleting the penalty of Rs. 1,28,78,000/= levied under Section 271 [1](c) of the Incometax Act with respect to addition of Rs. 6,43,60,0 .....

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..... re made and the issue was not free from doubt. In the opinion of the Tribunal, thus, the claim was not free from doubt or devoid of any basis. We further notice that the assessee in addition to having made full disclosure, also claimed that he had been under legal advice. The Tribunal also noted that even in quantum additions, the appeal is entertained by the High Court and is pending. No questio .....

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