#Inaccurate Particulars

ITAT Delhi sets aside a ₹12.91 lakh penalty under Section 271(1)(c) for failing to specify whether the charge was for concealment of income or furnishing inaccurate particulars. The ruling reinforces that tax authorities must clearly articulate the limb of the penalty provision invoked, impacting all penalty proceedings under the Income Tax Act.

ITAT Ahmedabad rules that penalty under Section 271(1)(c) cannot be imposed merely for a disallowed claim unless there is evidence of factual falsity or deliberate concealment. The tribunal set aside a ₹12.96 lakh penalty, emphasizing that audited accounts and disclosed claims negate allegations of inaccurate particulars.

The ITAT Bangalore has ruled that an assessee who fully discloses income but disputes its head of assessment cannot be penalized under Section 271(1)(c) for concealment or inaccurate particulars. This clarifies that legal interpretation differences, absent intent to evade, are not tax misconduct - protecting taxpayers from punitive action over bona fide accounting disagreements.