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Section 271(1)(c ) of the Income-tax Act, 1961 - Penalty - For concealment of income  Penalty could not be imposed where though assessee had disclosed enhanced compensation and interest thereon, yet but had not offered it for taxation in assessment year in question. [A.Y. 1998-99] The assessee had filed a return declaring income of Rs. 30.760 on 30-3-1999, in the status of individual. Though it declared enhanced compensation received at Rs. 7,68,172.75 and interest on enhanced compensation at Rs. 4,351 in the computation sheet, but it did not offer the same for taxation. Thereupon, penalty was imposed on the assessee under section 271(1)(c). The Tribunal deleted the penalty. Held that the matter relating to the enhanced compensation, was a highly debatable issue inasmuch as two views were clearly possible on the said issue. The claim of the assessee on the issue, thus, was based on one possible view and although the said claim was not accepted in the quantum proceedings in view of a difference of opinion, making of such claim bona fide on the basis of a possible view could not be treated as concealment of income by the assessee or furnishing of inaccurate particulars of such income so as to attract the penal provisions of section 271(1)(c). JUDGMENT Rakesh Kumar Garg, J.-The Revenue has filed the present appeal against the order dated April 19, 2007, passed by the Income-tax Appellate Tribunal, Delhi Bench "H", New Delhi, in I.T.A. No. 328/Delhi of 2006 in the case of the respondent/assessee for the assessment year 1998-99 raising the following substantial questions of law : "(i)Whether the hon'ble Income-tax Appellate Tribunal was right in law in deleting the penalty levied under section 271(1)(c) of the Income-tax Act, 1961, whereas it had already confirmed the addition made under section 45(5) of the Income-tax Act on account of enhanced compensation received during the previous year relating to the assessment year 1998-99 ? (ii)Whether, on the facts and circumstances of the case, the hon'ble Income-tax Appellate Tribunal was right in holding that the view of the assessee regarding non-taxability of enhanced compensation was bona fide particularly in view…

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