Tribunal held that when the disallowance of expenses on estimate basis and also on the issue whether allowable as revenue or Capital being a debatable issue, levy of penalty is not justified. Tribunal also held that when the disallowance was deleted , the Levy of penalty is not justified . ( AY.2002-03)
Piramal Healthcare Ltd. v .Dy. CIT (2020)82 ITR 47 (SN)(Mum) (Trib)
S. 271(1)(c) : Penalty – Concealment – Disallowance of expenses on estimate basis – Capital or revenue –Debatable issue – Levy of penalty is not justified – Disallowance was deleted -Levy of penalty is not justified . [ S.14A ]