Pricewaterhousecoopers Pvt.Ltd vs C.I.T-Kolkata-I & Anr

The Supreme Court held that the imposition of penalty under Section 271(1)(c) of the Income Tax Act, 1961 was unjustified as the assessee's claim for deduction of gratuity provision was inadvertent and overlooked by the Assessing Officer. The Court emphasized that the assessee had complied with statutory requirements under Sections 139(6) and 44AB, and the reopening of assessment under Section 148 was not warranted. Consequently, the penalty was set aside, although the quantum was reduced by the High Court.