Bench: SHRI INTURI RAMA RAO (Accountant Member), SHRI RAHUL CHAUDHARY (Judicial Member)
2) The Penalty is totally illegal, unwarranted and unsustainable since there is no deliberate attempt on the part of the appellant. Being a trust existing for uplift of the poor there cannot be any imputation of attempt to evade tax. The assessment was done purely based on a legal view which can have more views than one. The view taken