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C.I.T.,Ahmedabad vs Reliance Petroproducts Pvt.Ltd on 17 March, 2010

15. Now, coming to the merits of the addition, I find that as far as deduction for HRA was claimed by assessee, the same was denied only for the reason that actual payment had not been made by assessee. It is not disputed that the assessee was residing in the house of his mother to whom the rent was payable. Therefore, at best, it can be said to be a wrong claim in view of Explanation B to section 10(13A) but that does not imply that the assessee furnished any inaccurate particulars of its income. The amount was payable to mother and not to any outsider. This goes to show assessee's bona-fide. I, therefore, do not find any reason to saddle the assessee with penalty on account of claim of deduction of HRA made in the original return, in view of the decision of Hon'ble Supreme Court in the case of CIT vs. Reliance Petroporducts Pvt. Ltd., (2010) 322 ITR 158 (SC), wherein, it has been held as under :-
Supreme Court of India Cites 13 - Cited by 1723 - V S Sirpurkar - Full Document
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