Case Law Analysis
|Income Tax Appellate Tribunal
Section 271(1)(c) Income Tax Act | Penalty Invalid Where Disputed Issue Is Admitted as Substantial Question of Law by High Court : ITAT Mumbai
ITAT Mumbai holds that penalty under Section 271(1)(c) cannot be imposed when the tax dispute involves a substantial question of law already admitted by the High Court, recognizing such claims as bona fide and not constituting concealment. This shields taxpayers from punitive action when legal uncertainty exists at the appellate level, reinforcing the principle that penalty requires deliberate intent, not mere disagreement with tax authorities.