Shanti Prime Publication Pvt. Ltd.
Sec. 271(1)(c) & 274 of Income-tax Act, 1961 — Penalty - The assessee had declared the full facts and the sale agreement at the first instance; the full factual matrix or facts were before the AO while passing the assessment order. Thus the appellant had never suppressed any material fact from the respondent. It is another matter that the claim based on such facts was found to be inadmissible. This is not the same thing as furnishing inaccurate particulars of income as contemplated under s. 271(1)(c) of the Act. The order of Tribunal in confirming the levy of penalty under s. 271(1)(c) of the Act, set aside. - OMPRAKASH T. MEHTA V/s ITO - [2020] 316 CTR 280 (BOM)