In the result, all the appeals filed by the assessee are allowed and copy of common order passed is to be placed on respective case files
Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]
233 CTR 465 held that If assessee makes a claim which is not only incorrect in law, but is also wholly without any basis and explanation furnished by him for making such a claim is not found to be bona fide, Explanation 1 to section 271(1)(c) would come into play and assessee will be liable to penalty