K.J. IN THE HIGH COURT OF JUDICATURE AT BOMBAY ORDINARY ORIGINAL CIVIL JURISDICTION INCOME TAX APPEAL NO.341 OF 2005 The CIT-4 ..Appellant Versus Lallubhai Amichand Ltd., ..Respondent ---- Mr.B.M.Chatterji with Mrs.P.P.Bhosale & P.S.Sahadevan for the appellant. ---- Coram : F.I.Rebello & R.S.Mohite,JJ Coram : F.I.Rebello & R.S.Mohite,JJ Coram : F.I.Rebello & R.S.Mohite,JJ Date : 12.03.2008. PC 1. Commissioner (Appeals) after considering the various contentions held that the appellant company could not be held guilty of either having concealed its income or having furnished any inaccurate particulars of income. Further all the issues, as explained earlier were on points of law, which were debatable and accordingly, opined that penalty levied under Section 271(1) (c) in the case of the appellant company should be cancelled. 2. ITAT confirmed the order of Commissioner (Appeals) on the ground that it was merely a change of opinion. 3. We cannot find any fault either in the reasoning given by the Commissioner (Appeals) or the learned ITAT and consequently, appeal dismissed. (R.S.Mohite,J) (F.I.Rebello,J) (R.S.Mohite,J) (F.I.Rebello,J) (R.S.Mohite,J) (F.I.Rebello,J)