Bench: Us In This Regard Reads As Under: 1. On The Facts & In The Circumstances Of The Case & In Law The Learned Commissioner Of Income Tax (Appeals), Rajkot-1 Has Erred In Confirming The Order Passed By Assessing Officer U/S 271(L)(C) Of The Income Tax Act, 1961 Imposing A Penalty Of Rs. 18,50,900 On The Appellant Despite The Fact That The Claim For The Deduction Was Bona-Fide, The Details Furnished For The Claim For Allowance Were Not Found To Be Inaccurate & That There Was No Deliberate Attempt To Furnishing Of Inaccurate Particulars On The Part Of The Appellant Assesse. The Ao'S Action Being Erroneous On Facts & In Law, The Appellant Prays That The Penalty Of Rs. 18,50,900 Be Deleted..

36(1)(viia) of the Act. The same was disallowed in the assessment framed u/s 143(3) of the Act holding that such provisions for Standard assets do not qualify for deduction under the section as it relates only to bad and doubtful debts . Subsequently penalty u/s 271