The Income Tax Appellate Tribunal (ITAT) Delhi Bench addressed the appeal by GE Packaged Power Inc. against penalties imposed by the DCIT (International Taxation), Circle-1(3)(1), New Delhi, for the assessment year 2001-02 under ITA No. 765/DEL/2019.
GE Packaged Power Inc., based in Gurgaon, contested penalties levied under Section 271(1)(c) of the Income Tax Act, arguing multiple legal and procedural errors. This includes the debatable nature of the additions confirmed by ITAT, which were under appeal, and the claim that the penalties were imposed beyond the statutory limitation period.
The tribunal’s decision focused on whether the issues underlying the penalties were sufficiently debatable to warrant relief from penalties. It discussed precedents where penalties were canceled under similar circumstances, emphasizing the need for clear, substantive evidence of concealment or misreporting to uphold penalties under Section 271(1)(c).
The tribunal found in favor of GE Packaged Power Inc., setting aside the penalties based on the arguments presented about the debatable nature of the quantum additions and procedural lapses in penalty initiation. This decision highlights the importance of clear guidelines and adherence to procedural norms in tax penalty cases.
Appeal of GE Packaged Power Inc. on International Tax Penalties for AY 2001-02 (ITA 765/DEL/2019)
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