Dismissing the appeal of the revenue the Tribunal held that  ,where facts are on record and all information relating to expenditure  has been fully disclosed in the financial statements and there is only a difference of opinion between the assessee and the AO  regard the nature of expenditure . Deletion of penalty is held to be justified . (ITA No 1978 /Mum/2018 dt 11-10-2019 ) (AY. 2012 -13)