Held that the assessee had made full disclosure in the return of income while computing the book profits under section 115JB of the Act. The manner of computation may not be in accord with the view of the Assessing Officer, but that would not attract penalty provisions under section 271(1)(c). No penalty could have been levied on such disallowance or addition. (AY. 2004-05)
ASIT C. Mehta Investment Intermediates P. Ltd. v. Dy. CIT (2021) 90 ITR 7 (SN) (Mum.)(Trib.)
S. 271(1)(c) : Penalty-Concealment-Set off of unabsorbed depreciation and business losses-Making full disclosure-Penalty not sustainable. [S. 115JB]