The Assessing Officer levied penalty under section 271(1)(c) in respect of interest on delayed payment of licence fee after treating the expenditure as capital in nature. The Tribunal held that the issue had travelled up to the High Court and involved a bona fide legal dispute. At best, the expenditure was liable for amortisation under section 35ABB and could not give rise to penalty for concealment or furnishing inaccurate particulars. The penalty was rightly deleted. (AY. 1999-2000 & 2007-08).