CIT v M/s MANSUKH DEYING & PRINTING MILLS (Income Tax Appeal No.1133 of 2008 dtd 24/06/2013) Bombay High Court Background: During the assessment proceeding for the AY 1992-93, the AO had assessed an amount of Rs.2.63 Crores being goodwill as chargeable to capital gain tax on account of the fact that the above amount was debited to partners capital accounts during the AY 1992-93. The AO while passing the assessment order also directed that penalty proceedings be initiated under Section 271(1)(c) of the said Act against the assessee.