rl #L % 30.o5.201L Present: Mr. N.P. Sahni, Sr. Standing Counsel with Mr' Ruchesh Sinha, Adv. for the Revenue. Mr. Prakash Kumar, Adv. for the assessee. +lTA No. L4O|2OLL * Addition was made, in the quantum proceedings, solely on the basis of deeming provisions made in Section 50C of the lncome Tax Act. The deemed value provided in the said Section is not an absolute value. After the addition was made, penalty proceedings were started and penalty imposed which have been deleted by the Income Tax Appellate Tribunal , inter alia, on the ground that it was not a case where the assessee had furnished inaccurate particular. In fact, provisions of Section 50C of the Act were inserted in that very assessment year i.e. 2003-04 which were interpreted by the assessee in a particular way by discussing all the relevant facts in the income tax return. lf the legal position taken by him was not accepted and the addition was made, that would not call for penalty' We do not see any substantial question of law which arises for consideration in this case. This appeal is dismissed accordingly' n ,.(h.il-A. i.,41 a stKRl, J. MAY 3O, 2olllpmc M.L. MEHTA, J. Digitally Signed By:AMULYA Certify that the digital file and physical file have been compared and the digital data is as per the physical file and no page is missing. Signature Not Verified