CIT v. Reliance Petro Products (P) Limited

256 ITR 683High Court2002#4492 most cited

What is CIT v. Reliance Petro Products (P) Limited authority for?

Penalty under section 271(1)(c) cannot be levied if a substantial question of law is framed and admitted by the High Court or Supreme Court.

26

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2015 to 2025.

Also referred to as

CIT v. Reliance Petro Products · section 271(1)(c) · penalty · concealment of income · inaccurate particulars · substantial question of law · section 260A

Sections most often in play

Section 143(3)Section 14ASection 260ASection 271(1)(c)Section 35ABB

Issues it is cited on

section 274(1)section 43b(f)section 2(45)section 36(l)(iii)section 211section 271(l)section 32(1)(iia)house property incomesection 140full and true disclosuresection 271(l)(c)additional depreciation

Judgments citing CIT v. Reliance Petro Products (P) Limited

ACIT, CIRCLE- 26(2), NEW DELHI vs. VODAFONE IDEA LTD. (EARLIER KNWON AS VODAFONE MOBILE SERVICES LTD.), NEW DELHI

ITA 8079/DEL/2018[2007-08]Status: DisposedITAT Delhi21 Mar 2025AY 2007-08

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 1999-2000 Vs. M/S. Vodafone West Ltd. Acit, Circle-26(2), (Thereafter Merged With New Delhi Vodafone Mobile Services Ltd.), C-48, Okhla Industrial Area, Phase-2, New Delhi Pan: Aaacf1190P (Appellant) (Respondent) With Assessment Year: 2007-08 Vs. M/S. Vodafone Idea Ltd. Acit, Circle-26(2), (Earlier Known As Vodafone New Delhi Mobile Services Ltd.), C-48, Okhla Industrial Area, Phase-2, New Delhi Pan: Aaacb2100P (Appellant) (Respondent) Assessee By Sh. Salil Kapoor, Adv. Sh. Anil Chachra, Adv. Ms. Ananya Kapoor, Adv. Department By Sh. Vijay B. Basanta, Cit(Dr) Date Of Hearing 06.03.2025 Date Of Pronouncement 21.03.2025 Order Per Satbeer Singh Godara, Jm These Revenue’S Appeals Ita No.7658/Del/2018 & 8079/Del/2018 For Assessment Years 1999-2000 & 2007-08

Section 271(1)(c)

…h Court); Vijayshree Realty Pvt. Ltd Vs ITO Ward 9 (3) (2007 TIOL 444) (Mumbai ITAT); CIT v Harshvardhan Chemicals and Mineral Ltd. (259 ITR 212) (Rajasthan High Court); CIT vs GD Naidu and Others (1987) 165 ITR 63 (Madras), CIT vs Sivananda Steels Ltd (2002) 256 ITR 683 (Madras); and Commissioner of Income tax vs Ajaib Singh and Co (2002) 253 ITR 630 (Punjab and Haryana High Court). Further, in any case, it is well settled that that no penalty under section 271(1)(c) of the Act can be levied in a case where a substantial question of law is framed and admitted by the Hon'ble High Court or the Hon'ble Supreme Cour…

ACIT, CIRCLE-26(2), NEW DELHI vs. VODAFONE WEST LTD., (THEREAFTER MERGED WITH VODAFONE MOBILE SERVICES LTD.),, NEW DELHI

ITA 7658/DEL/2018[1999-2000]Status: DisposedITAT Delhi21 Mar 2025AY 1999-2000

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 1999-2000 Vs. M/S. Vodafone West Ltd. Acit, Circle-26(2), (Thereafter Merged With New Delhi Vodafone Mobile Services Ltd.), C-48, Okhla Industrial Area, Phase-2, New Delhi Pan: Aaacf1190P (Appellant) (Respondent) With Assessment Year: 2007-08 Vs. M/S. Vodafone Idea Ltd. Acit, Circle-26(2), (Earlier Known As Vodafone New Delhi Mobile Services Ltd.), C-48, Okhla Industrial Area, Phase-2, New Delhi Pan: Aaacb2100P (Appellant) (Respondent) Assessee By Sh. Salil Kapoor, Adv. Sh. Anil Chachra, Adv. Ms. Ananya Kapoor, Adv. Department By Sh. Vijay B. Basanta, Cit(Dr) Date Of Hearing 06.03.2025 Date Of Pronouncement 21.03.2025 Order Per Satbeer Singh Godara, Jm These Revenue’S Appeals Ita No.7658/Del/2018 & 8079/Del/2018 For Assessment Years 1999-2000 & 2007-08

Section 271(1)(c)

…h Court); Vijayshree Realty Pvt. Ltd Vs ITO Ward 9 (3) (2007 TIOL 444) (Mumbai ITAT); CIT v Harshvardhan Chemicals and Mineral Ltd. (259 ITR 212) (Rajasthan High Court); CIT vs GD Naidu and Others (1987) 165 ITR 63 (Madras), CIT vs Sivananda Steels Ltd (2002) 256 ITR 683 (Madras); and Commissioner of Income tax vs Ajaib Singh and Co (2002) 253 ITR 630 (Punjab and Haryana High Court). Further, in any case, it is well settled that that no penalty under section 271(1)(c) of the Act can be levied in a case where a substantial question of law is framed and admitted by the Hon'ble High Court or the Hon'ble Supreme Cour…

SOUTH EASTERN COALFIELDS LIMITED, BILASPUR,BILASPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1), BILASPUR, BILASPUR

ITA 42/RPR/2023[2016-17]Status: DisposedITAT Raipur09 Jun 2023AY 2016-17

Bench: Shri Ravish Sood & Shri Arun Khodpia

Section 271(1)(c)

…e reason that there is no inaccurate particulars filed by the appellant company in the return of any of the earlier years. The Ld. AR placed reliance in the decision in CIT Vs. Reliance Petro Products (P) Limited 322 ITR 158; CIT Vs. Sivananda Steels Limited 256 ITR 683 (Mad); CIT Vs. Dhoolie Tea Co. Ltd 231 ITR 65 (Cal); Township Read Estate Developers (India) (P) Ltd Vs. ACIT 21 taxman.com 63 (Mum) and submitted that there is no element of either concealment of income or furnishing of inaccurate particulars of income in the return in view of provisions of section 271(1)(c) and hence, penalty imposed by the Ld.…

SOUTH EASTERN COALFIELDS LIMITED, BILASPUR,BILASPUR vs. ASSISSTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1), BILASPUR, BILASPUR

ITA 41/RPR/2023[2015-16]Status: DisposedITAT Raipur09 Jun 2023AY 2015-16

Bench: Shri Ravish Sood & Shri Arun Khodpia

Section 271(1)(c)

…e reason that there is no inaccurate particulars filed by the appellant company in the return of any of the earlier years. The Ld. AR placed reliance in the decision in CIT Vs. Reliance Petro Products (P) Limited 322 ITR 158; CIT Vs. Sivananda Steels Limited 256 ITR 683 (Mad); CIT Vs. Dhoolie Tea Co. Ltd 231 ITR 65 (Cal); Township Read Estate Developers (India) (P) Ltd Vs. ACIT 21 taxman.com 63 (Mum) and submitted that there is no element of either concealment of income or furnishing of inaccurate particulars of income in the return in view of provisions of section 271(1)(c) and hence, penalty imposed by the Ld.…

SOUTH EASTERN COALFIELDS LIMITED, BILASPUR,BILASPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1), BILASPUR, BILASPUR

ITA 40/RPR/2023[2014-15]Status: DisposedITAT Raipur09 Jun 2023AY 2014-15

Bench: Shri Ravish Sood & Shri Arun Khodpia

Section 271(1)(c)

…e reason that there is no inaccurate particulars filed by the appellant company in the return of any of the earlier years. The Ld. AR placed reliance in the decision in CIT Vs. Reliance Petro Products (P) Limited 322 ITR 158; CIT Vs. Sivananda Steels Limited 256 ITR 683 (Mad); CIT Vs. Dhoolie Tea Co. Ltd 231 ITR 65 (Cal); Township Read Estate Developers (India) (P) Ltd Vs. ACIT 21 taxman.com 63 (Mum) and submitted that there is no element of either concealment of income or furnishing of inaccurate particulars of income in the return in view of provisions of section 271(1)(c) and hence, penalty imposed by the Ld.…

SOUTH EASTERN COALFIELDS LIMITED, BILASPUR,BILASPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1), BILASPUR, BILASPUR

ITA 39/RPR/2023[2013-14]Status: DisposedITAT Raipur09 Jun 2023AY 2013-14

Bench: Shri Ravish Sood & Shri Arun Khodpia

Section 271(1)(c)

…e reason that there is no inaccurate particulars filed by the appellant company in the return of any of the earlier years. The Ld. AR placed reliance in the decision in CIT Vs. Reliance Petro Products (P) Limited 322 ITR 158; CIT Vs. Sivananda Steels Limited 256 ITR 683 (Mad); CIT Vs. Dhoolie Tea Co. Ltd 231 ITR 65 (Cal); Township Read Estate Developers (India) (P) Ltd Vs. ACIT 21 taxman.com 63 (Mum) and submitted that there is no element of either concealment of income or furnishing of inaccurate particulars of income in the return in view of provisions of section 271(1)(c) and hence, penalty imposed by the Ld.…

SOUTH EASTERN COALFIELDS LIMITED,BILASPUR vs. JT. COMMISSIONER OF INCOME TAX (OSD), CIRCLE-1(1), BILASPUR

ITA 66/RPR/2021[2010-11]Status: DisposedITAT Raipur09 Jun 2023AY 2010-11

Bench: Shri Ravish Sood & Shri Arun Khodpia

Section 271(1)(c)

…e reason that there is no inaccurate particulars filed by the appellant company in the return of any of the earlier years. The Ld. AR placed reliance in the decision in CIT Vs. Reliance Petro Products (P) Limited 322 ITR 158; CIT Vs. Sivananda Steels Limited 256 ITR 683 (Mad); CIT Vs. Dhoolie Tea Co. Ltd 231 ITR 65 (Cal); Township Read Estate Developers (India) (P) Ltd Vs. ACIT 21 taxman.com 63 (Mum) and submitted that there is no element of either concealment of income or furnishing of inaccurate particulars of income in the return in view of provisions of section 271(1)(c) and hence, penalty imposed by the Ld.…

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE -1(1), BILASPUR vs. SOUTH EASTERN COALFIELDS LIMITED, BILASPUR

ITA 170/RPR/2018[2012-13]Status: DisposedITAT Raipur09 Jun 2023AY 2012-13

Bench: Shri Ravish Sood & Shri Arun Khodpia

Section 271(1)(c)

…e reason that there is no inaccurate particulars filed by the appellant company in the return of any of the earlier years. The Ld. AR placed reliance in the decision in CIT Vs. Reliance Petro Products (P) Limited 322 ITR 158; CIT Vs. Sivananda Steels Limited 256 ITR 683 (Mad); CIT Vs. Dhoolie Tea Co. Ltd 231 ITR 65 (Cal); Township Read Estate Developers (India) (P) Ltd Vs. ACIT 21 taxman.com 63 (Mum) and submitted that there is no element of either concealment of income or furnishing of inaccurate particulars of income in the return in view of provisions of section 271(1)(c) and hence, penalty imposed by the Ld.…

SOUTH EASTERN COALFIELDS LIMITED,BILASPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE -1(1), BILASPUR

ITA 167/RPR/2018[2012-13]Status: DisposedITAT Raipur09 Jun 2023AY 2012-13

Bench: Shri Ravish Sood & Shri Arun Khodpia

Section 271(1)(c)

…e reason that there is no inaccurate particulars filed by the appellant company in the return of any of the earlier years. The Ld. AR placed reliance in the decision in CIT Vs. Reliance Petro Products (P) Limited 322 ITR 158; CIT Vs. Sivananda Steels Limited 256 ITR 683 (Mad); CIT Vs. Dhoolie Tea Co. Ltd 231 ITR 65 (Cal); Township Read Estate Developers (India) (P) Ltd Vs. ACIT 21 taxman.com 63 (Mum) and submitted that there is no element of either concealment of income or furnishing of inaccurate particulars of income in the return in view of provisions of section 271(1)(c) and hence, penalty imposed by the Ld.…

THE DEPUTY COMMISSIONER OF INCOME TAX,CIRCLE 1(1)BILASPUR, BILASPUR(CG) vs. THE SOUTH EASTERN COAL FIELDS LTD., BILASPUR, BILASPUR(CG)

ITA 97/BIL/2017[2011-12]Status: DisposedITAT Raipur09 Jun 2023AY 2011-12

Bench: Shri Ravish Sood & Shri Arun Khodpia

Section 271(1)(c)

…e reason that there is no inaccurate particulars filed by the appellant company in the return of any of the earlier years. The Ld. AR placed reliance in the decision in CIT Vs. Reliance Petro Products (P) Limited 322 ITR 158; CIT Vs. Sivananda Steels Limited 256 ITR 683 (Mad); CIT Vs. Dhoolie Tea Co. Ltd 231 ITR 65 (Cal); Township Read Estate Developers (India) (P) Ltd Vs. ACIT 21 taxman.com 63 (Mum) and submitted that there is no element of either concealment of income or furnishing of inaccurate particulars of income in the return in view of provisions of section 271(1)(c) and hence, penalty imposed by the Ld.…

THE SOUTH EASTERN COAL FIELDS LTD., BILASPUR,BILASPUR(CG) vs. THE DY. COMMISSIONER OF INCOME TAX,CIRCLE , 1(1)BILASPUR, BILASPUR(CG)

ITA 163/BIL/2017[2010-11]Status: DisposedITAT Raipur09 Jun 2023AY 2010-11

Bench: Shri Ravish Sood & Shri Arun Khodpia

Section 271(1)(c)

…e reason that there is no inaccurate particulars filed by the appellant company in the return of any of the earlier years. The Ld. AR placed reliance in the decision in CIT Vs. Reliance Petro Products (P) Limited 322 ITR 158; CIT Vs. Sivananda Steels Limited 256 ITR 683 (Mad); CIT Vs. Dhoolie Tea Co. Ltd 231 ITR 65 (Cal); Township Read Estate Developers (India) (P) Ltd Vs. ACIT 21 taxman.com 63 (Mum) and submitted that there is no element of either concealment of income or furnishing of inaccurate particulars of income in the return in view of provisions of section 271(1)(c) and hence, penalty imposed by the Ld.…

SOUTH EASTERN COAL FIELDS LTD.,,BILASPUR(CG) vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE -1(1), BILASPUR(CG)

ITA 144/BIL/2017[2011-12]Status: DisposedITAT Raipur09 Jun 2023AY 2011-12

Bench: Shri Ravish Sood & Shri Arun Khodpia

Section 271(1)(c)

…e reason that there is no inaccurate particulars filed by the appellant company in the return of any of the earlier years. The Ld. AR placed reliance in the decision in CIT Vs. Reliance Petro Products (P) Limited 322 ITR 158; CIT Vs. Sivananda Steels Limited 256 ITR 683 (Mad); CIT Vs. Dhoolie Tea Co. Ltd 231 ITR 65 (Cal); Township Read Estate Developers (India) (P) Ltd Vs. ACIT 21 taxman.com 63 (Mum) and submitted that there is no element of either concealment of income or furnishing of inaccurate particulars of income in the return in view of provisions of section 271(1)(c) and hence, penalty imposed by the Ld.…

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE -1(1), BILASPUR(CG) vs. SOUTH EASTERN COAL FIELDS LTD.,, BILASPUR(CG)

ITA 143/BIL/2017[2010-11]Status: DisposedITAT Raipur09 Jun 2023AY 2010-11

Bench: Shri Ravish Sood & Shri Arun Khodpia

Section 271(1)(c)

…e reason that there is no inaccurate particulars filed by the appellant company in the return of any of the earlier years. The Ld. AR placed reliance in the decision in CIT Vs. Reliance Petro Products (P) Limited 322 ITR 158; CIT Vs. Sivananda Steels Limited 256 ITR 683 (Mad); CIT Vs. Dhoolie Tea Co. Ltd 231 ITR 65 (Cal); Township Read Estate Developers (India) (P) Ltd Vs. ACIT 21 taxman.com 63 (Mum) and submitted that there is no element of either concealment of income or furnishing of inaccurate particulars of income in the return in view of provisions of section 271(1)(c) and hence, penalty imposed by the Ld.…

SOUTH EASTERN COALFIELDS LTD,BILASPUR(CG) vs. DY.. C.I.T.-1(1), BILASPUR(CG)

ITA 156/BIL/2014[2009-10]Status: DisposedITAT Raipur09 Jun 2023AY 2009-10

Bench: Shri Ravish Sood & Shri Arun Khodpia

Section 271(1)(c)

…e reason that there is no inaccurate particulars filed by the appellant company in the return of any of the earlier years. The Ld. AR placed reliance in the decision in CIT Vs. Reliance Petro Products (P) Limited 322 ITR 158; CIT Vs. Sivananda Steels Limited 256 ITR 683 (Mad); CIT Vs. Dhoolie Tea Co. Ltd 231 ITR 65 (Cal); Township Read Estate Developers (India) (P) Ltd Vs. ACIT 21 taxman.com 63 (Mum) and submitted that there is no element of either concealment of income or furnishing of inaccurate particulars of income in the return in view of provisions of section 271(1)(c) and hence, penalty imposed by the Ld.…

THE DY. CIT- CIR.-1(1),, BILASPUR(CG) vs. SOUTH EASTERN COALFILDS LTD.,, BILASPUR(CG)

ITA 152/BIL/2014[2009-10]Status: DisposedITAT Raipur09 Jun 2023AY 2009-10

Bench: Shri Ravish Sood & Shri Arun Khodpia

Section 271(1)(c)

…e reason that there is no inaccurate particulars filed by the appellant company in the return of any of the earlier years. The Ld. AR placed reliance in the decision in CIT Vs. Reliance Petro Products (P) Limited 322 ITR 158; CIT Vs. Sivananda Steels Limited 256 ITR 683 (Mad); CIT Vs. Dhoolie Tea Co. Ltd 231 ITR 65 (Cal); Township Read Estate Developers (India) (P) Ltd Vs. ACIT 21 taxman.com 63 (Mum) and submitted that there is no element of either concealment of income or furnishing of inaccurate particulars of income in the return in view of provisions of section 271(1)(c) and hence, penalty imposed by the Ld.…

THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, BARODA vs. M/S. SUN PHARMACEUTICALS INDUSTRIES LIMITED,, VADODARA

In the result the appeal of the revenue is dismissed

ITA 347/AHD/2017[2001-02]Status: DisposedITAT Ahmedabad12 Jul 2019AY 2001-02

Bench: The Itat Ahmedabad Vide Ita No. 3289/Ahd/2002 & 3343/Ahd/2002. Addition On Account Of Profit On Sale Of Depb For The Purpose Of Rs.11,41,480 Deduction U/S.80Ia Deduction U/S.115Jb(2) In Respect Of Book Losses Of Pradeep Drug Rs.3, 39,12,399

For Appellant: Shri Bandish Soparkar, A.RFor Respondent: Shri Mudit Nagpal, Sr. D.R
Section 115JSection 143(3)Section 271Section 271(1)Section 271(1)(c)Section 271(16)Section 274Section 80I

…271(l)(c) cannot be imposed in respect of additions made on debatable issues. A few of such decisions are as under:- a) Nalwa Sons Investments Ltd. 235 CTR 209 (Del.) b) Karan Raghav Export Exports Pvt. Ltd. (2012) 349 ITR 112 (Del.) c) Sivananda Steels Ltd. 256 ITR 683 (Mad.) In view of the above facts and legal position, thus I hold that no penalty is imposable in respect of disallowance of deduction u/s. 80IA on profit arising from DEPB. 4.3. Ground No. 4 pertains to disallowance of claim of losses reduced from the book profit computed u/s. 115JB pertaining to Pradeep Drug Co. Ltd. which had amalgamated with…

M/S INDUSTRIAL FILTERS & FABRICS PVT.LTD.,INDORE vs. THE JCIT, R-5 (PRESENT AO: DCIT 2(1), INDORE

In the result, the appeals filed by the assessee

ITA 961/IND/2016[2011-12]Status: DisposedITAT Indore23 Aug 2018AY 2011-12

Bench: Shri Kul Bharat & Shri Manish Boradassessment Year: 2007-08

Section 133(6)Section 143(3)Section 68

…Vs. Amarnath (143 CTR 148) (All.) 3. 3. CIT Vs. Amarnath (143 CTR 148) (All.) CIT Vs. Amarnath (143 CTR 148) (All.) CIT Vs. Amarnath (143 CTR 148) (All.) It was held that no penalty could be levied when two views are possible. 4. 4. CIT Vs. Sivananda Steels (256 ITR 683) (Mad.) 4. 4. CIT Vs. Sivananda Steels (256 ITR 683) (Mad.) CIT Vs. Sivananda Steels (256 ITR 683) (Mad.) CIT Vs. Sivananda Steels (256 ITR 683) (Mad.) It has been held that the difference of opinion between the Assessing Officer and the assessee cannot be regarded as sufficient to subject the assessee to penalty on the ground that the particular…

M/S INDUSTRIAL FILTERS & FABRICS PRIVATE LIMITED,INDORE vs. THE ACIT 2(1), INDORE

In the result, the appeals filed by the assessee

ITA 753/IND/2016[2008-09]Status: DisposedITAT Indore23 Aug 2018AY 2008-09

Bench: Shri Kul Bharat & Shri Manish Boradassessment Year: 2007-08

Section 133(6)Section 143(3)Section 68

…Vs. Amarnath (143 CTR 148) (All.) 3. 3. CIT Vs. Amarnath (143 CTR 148) (All.) CIT Vs. Amarnath (143 CTR 148) (All.) CIT Vs. Amarnath (143 CTR 148) (All.) It was held that no penalty could be levied when two views are possible. 4. 4. CIT Vs. Sivananda Steels (256 ITR 683) (Mad.) 4. 4. CIT Vs. Sivananda Steels (256 ITR 683) (Mad.) CIT Vs. Sivananda Steels (256 ITR 683) (Mad.) CIT Vs. Sivananda Steels (256 ITR 683) (Mad.) It has been held that the difference of opinion between the Assessing Officer and the assessee cannot be regarded as sufficient to subject the assessee to penalty on the ground that the particular…

M/S INDUSTRIAL FILTERS & FABRICS PRIVATE LIMITED,INDORE vs. THE ACIT 2(1), INDORE

In the result, the appeals filed by the assessee

ITA 752/IND/2016[2007-08]Status: DisposedITAT Indore23 Aug 2018AY 2007-08

Bench: Shri Kul Bharat & Shri Manish Boradassessment Year: 2007-08

Section 133(6)Section 143(3)Section 68

…Vs. Amarnath (143 CTR 148) (All.) 3. 3. CIT Vs. Amarnath (143 CTR 148) (All.) CIT Vs. Amarnath (143 CTR 148) (All.) CIT Vs. Amarnath (143 CTR 148) (All.) It was held that no penalty could be levied when two views are possible. 4. 4. CIT Vs. Sivananda Steels (256 ITR 683) (Mad.) 4. 4. CIT Vs. Sivananda Steels (256 ITR 683) (Mad.) CIT Vs. Sivananda Steels (256 ITR 683) (Mad.) CIT Vs. Sivananda Steels (256 ITR 683) (Mad.) It has been held that the difference of opinion between the Assessing Officer and the assessee cannot be regarded as sufficient to subject the assessee to penalty on the ground that the particular…

M/S INDUSTRIAL FILTERS & FABRICS PRIVATE LIMITED,INDORE vs. THE ACIT-2(1), INDORE

In the result, the appeals filed by the assessee

ITA 293/IND/2016[2012-13]Status: DisposedITAT Indore23 Aug 2018AY 2012-13

Bench: Shri Kul Bharat & Shri Manish Boradassessment Year: 2007-08

Section 133(6)Section 143(3)Section 68

…Vs. Amarnath (143 CTR 148) (All.) 3. 3. CIT Vs. Amarnath (143 CTR 148) (All.) CIT Vs. Amarnath (143 CTR 148) (All.) CIT Vs. Amarnath (143 CTR 148) (All.) It was held that no penalty could be levied when two views are possible. 4. 4. CIT Vs. Sivananda Steels (256 ITR 683) (Mad.) 4. 4. CIT Vs. Sivananda Steels (256 ITR 683) (Mad.) CIT Vs. Sivananda Steels (256 ITR 683) (Mad.) CIT Vs. Sivananda Steels (256 ITR 683) (Mad.) It has been held that the difference of opinion between the Assessing Officer and the assessee cannot be regarded as sufficient to subject the assessee to penalty on the ground that the particular…

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CIT v. Reliance Petro Products (P) Limited (256 ITR 683) — Cited in 26 Judgments | BharatTax