IN THE HIGH COURT OF JUDICATURE AT BOMBAY ORDINARY ORIGINAL CIVIL JURISDICTION INCOME TAX APPEAL (LDG.) NO. 887 OF 2009 The Commissioner of Income-tax-, ... Appellant. V/s. M/s.Autoriders Finance P.Ltd. ... Respondent. Suresh Kumar for the appellant. CORAM : V.C.DAGA AND J.P.DEVADHAR, JJ. DATED : 20th July 2009. P.C. : Heard. Office objections are over-ruled. Appeal is taken up for hearing at the request of the appellant. 2. Both parties agree that the issue sought to be raised in this appeal relates to penalty under section 271(1)(c) of the Income Tax Act. The Tribunal has dealt with the said issue in the following words: ..... It is only the rejection of the method of accounting adopted by the assessee which resulted in the addition and the Assessing Officer disallowed some legal and professional charges and brought to tax notional interest on interest paid advances. We are in agreement with the findings of the CIT(A) that there is no case for levy of penalty where there is a change of opinion and two different views are possible on the same issue assessee cannot be penalised for canvassing a view different from the departmental view. In view of this we upheld the order of the CIT(A) 3. Having seen the aforesaid finding, we see no substantial question of law involved in this appeal. Appeal is, therefor, dismissed in limine with no order as to costs. (J.P.DEVADHAR, J.) (V.C.DAGA J.)