2024 (8) TMI 1123

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... e relevant details - HELD THAT:- Even the Revenue could not rebut the clinching fact that such a failure on assessee s part in filing all the relevant details along with the return and lack of substantiation thereof on his part, would hardly invite the impugned penal provision as per CIT vs. Reliance Petro Products (P) Ltd., [ 2010 (3) TMI 80 - SUPREME COURT ] wherein their lordships have settled .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... It emerges at the outset that both the learned lower authorities have levied the impugned sec.271(1)(c) penalty in assessee s case amounting to Rs. 75 lakhs pertaining to the quantum disallowance of interest u/sec. 57(iii) of the Act wherein the taxpayer had claimed interest expenditure against interest income which he failed to substantiate despite filing all the relevant details. 3. Suffice to s .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X