2011 (5) TMI 1120

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..... nt years 2004-05 and 2005-06 are directed against orders of the Commissioner of Income-tax (Appeals). Since identical issue is involved in these two appeals preferred by the assessee, these are being disposed off with this consolidated order. 2. Identical issue involved in both these appeals preferred by the assessee is regarding validity of the penalty imposed under S.271(1)(c) of the Income-t .....

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..... cation of money was for non-business purposes and still the assessee made a wrong claim of deduction of interest and that in the facts of the case it could not be said that the assessee was not aware of the fact of application of money for non-business purposes by the assessee. He referred to the relevant paras of the orders of the assessing officer and the CIT(A) in support of the case of the Rev .....

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..... e case that the assessee has filed inaccurate particulars of its income by claiming certain deduction of interest in its computation of income. It is a case of honest difference of opinion between the assessee and the Revenue relating to allowance of certain expenses claimed by the assessee. The explanation of the assessee could not be said to be without any basis or foundation. In these facts of .....

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