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TMI Blog2020 (12) TMI 521X X X X Extracts X X X X X X X X Extracts X X X X ..... case of difference of opinion between the assessee and the AO on the facts already disclosed by the assessee. Merely because the AO treated the amount of income already offered differently from the one portrayed by the assessee, cannot in our considered opinion be a cause for imposing penalty u/s. 271(1)(c) - The Hon ble Supreme Court in CIT Vs. Reliance Petro products [ 2010 (3) TMI 80 - SUPREME ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... y precedent has been brought on record by the ld. DR. We, therefore, uphold the deletion of penalty. - Decided against revenue. X X X X Extracts X X X X X X X X Extracts X X X X ..... e of such land and tax was accordingly paid. The AO treated the gain arising from the transfer of such land as "Business income" instead of long term capital gain as offered. It is a case of difference of opinion between the assessee and the AO on the facts already disclosed by the assessee. Merely because the AO treated the amount of income already offered differently from the one portr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... against which the Revenue has come up in appeal before the Tribunal. 5. We have heard the ld. DR and gone through the relevant material on record. It is seen from the impugned order that the assessee incurred foreign tour expenses for conducting meetings with cement dealers of India Cement Ltd. and Visaka Industries Ltd., for which it was acting as C & F agent. These expenses included some amount ..... X X X X Extracts X X X X X X X X Extracts X X X X
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