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“concealment of income”

PenaltySection 271(1)(c)Section 271(1)(c)2,901 judgments

The decision most relied on for concealment of income is CIT v. Manjunatha Cotton & Ginning Factory (359 ITR 565), cited in 2,590 judgments on BharatTax.

Leading authorities on concealment of income

CIT v. Manjunatha Cotton & Ginning Factory
359 ITR 565 · 2013 · High Court
2,590
citing judgments

A penalty notice issued under section 274 read with section 271(1)(c) is invalid if it fails to specify whether the penalty proceedings are initiated for concealment of income or for furnishing inaccurate particulars of income. This non-specification vitiates the penalty proceedings.

CIT v. Reliance Petroproducts Pvt. Ltd.
322 ITR 158 · 2010 · Supreme Court
2,228
citing judgments

Penalty under Section 271(1)(c) for furnishing inaccurate particulars or concealment of income is not automatically leviable if the assessee has made a full disclosure of all particulars and the addition or disallowance arises from a difference of opinion.

CIT v. SSA’s Emerald Meadows
73 Taxmann.com 248 · 2016 · Supreme Court
953
citing judgments

A notice issued under Section 274 read with Section 271(1)(c) is invalid if it fails to specify whether penalty proceedings are for concealment of particulars of income or furnishing inaccurate particulars of income. Such lack of specificity vitiates the penalty proceedings.

Ashok Pai v. CIT
292 ITR 11 · 2007 · Supreme Court
812
citing judgments

“Concealment of particulars of income” and “furnishing inaccurate particulars of income” are two distinct offences under Section 271(1)(c) of the Income Tax Act. A penalty cannot be levied under one limb if the show cause notice or basis for penalty specifies the other, as this constitutes a complete variance in the reasons for assuming jurisdiction.

CIT v. SSA’s Emerald Meadows
73 Taxmann.com 241 · 2016 · High Court
791
citing judgments

A penalty notice under section 271(1)(c) read with section 274 of the Income Tax Act is invalid if it fails to specify whether the penalty is for concealment of income or for furnishing incorrect particulars of income.

Mr. Mohd. Farhan A. Shaikh v. ACIT
434 ITR 1 · 2021 · High Court
672
citing judgments

A penalty notice issued under section 274 read with section 271(1)(c) is invalid if it fails to specify the exact charge by not striking off the irrelevant limb (concealment of income or furnishing inaccurate particulars of income). Such an omnibus or vague notice renders the penalty proceedings bad in law, and any penalty imposed on its basis is liable to be quashed.

Dilip N. Shroff v. JCIT
291 ITR 519 · 2007 · Supreme Court
565
citing judgments

A penalty notice issued under Section 271(1)(c) is invalid if the Assessing Officer fails to strike out the inapplicable limb (concealment or furnishing inaccurate particulars) from the standard proforma, indicating non-application of mind. The initial burden of proving concealment or inaccurate particulars rests on the Revenue.

CIT v. Kaushalya
216 ITR 660 · 1995 · High Court
511
citing judgments

A penalty levied under Section 271(1)(c) for concealment or furnishing inaccurate particulars of income is not invalidated by the Assessing Officer's failure to strike off irrelevant portions in the show cause notice, provided the assessee understood the exact charge and suffered no prejudice, indicating an application of mind by the AO.

Judgments citing concealment of income

Deputy Commissioner of Income Tax, Central Circle 1 Noida, Noida vs. Sanjay Singh, Noida

In the result, both appeals filed by the Revenue are dismissed and C

ITA 2276/DEL/2023[2016-17]Status: DisposedITAT Delhi28 Nov 2024AY 2016-17

Bench: Shri Yogesh Kumar Us & Shri Avdhesh Kumar Mishra

Section 132(4)Section 269SSection 69A

very casually used the proforma used for issuing notice before levying penalty u/s 271(1)(c) of the Act for the concealment of income or furnishing of inaccurate particulars of income. Except mentioning the Section 271AAB of the Act in the notice it does not talk anything about the provision ... very casually used the proforma used for issuing notice before levying penalty u/s 271(1)(c) of the Act for the concealment of income or furnishing of inaccurate particulars of income. Except mentioning the section 271AAB of the Act in the notice, it does not talk anything about the provisions

DCIT Central Circle-I, Greater Noida vs. Sanjay Singh, Noida

In the result, both appeals filed by the Revenue are dismissed and C

ITA 6942/DEL/2019[2016-17]Status: DisposedITAT Delhi28 Nov 2024AY 2016-17

Bench: Shri Yogesh Kumar Us & Shri Avdhesh Kumar Mishra

Section 132(4)Section 269SSection 69A

very casually used the proforma used for issuing notice before levying penalty u/s 271(1)(c) of the Act for the concealment of income or furnishing of inaccurate particulars of income. Except mentioning the Section 271AAB of the Act in the notice it does not talk anything about the provision ... very casually used the proforma used for issuing notice before levying penalty u/s 271(1)(c) of the Act for the concealment of income or furnishing of inaccurate particulars of income. Except mentioning the section 271AAB of the Act in the notice, it does not talk anything about the provisions

Hamaja Mohammed Malpekar, Ratnagiri vs. Income Tax Officer, Ratnagiri Ward, Ratnagiri

ITA 264/PUN/2024[AY 2016-17]Status: DisposedITAT Pune27 Nov 2024

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Pramod S. ShingteFor Respondent: Shri Ramnath P. Murkunde
Section 143(2)Section 14ASection 194C

same amount as unexplained cash credits u/s 68 of the I.T. Act 1961. Penalty proceedings u/s. 271(1)(c) are hereby initiated for concealment of income to the tune of Rs.2,00,000/- (iii) Addition of Rs.6,45,95,500/- comprising of Rs.1,65,66,500/-, Rs.4

Assistant Commissioner of Income Tax, Cirle 1, Kolhapur vs. Hamaja Mohammed Malpekar, Maharashtra

ITA 23/PUN/2024[2016-17]Status: DisposedITAT Pune27 Nov 2024AY 2016-17

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Pramod S. ShingteFor Respondent: Shri Ramnath P. Murkunde
Section 143(2)Section 14ASection 194C

same amount as unexplained cash credits u/s 68 of the I.T. Act 1961. Penalty proceedings u/s. 271(1)(c) are hereby initiated for concealment of income to the tune of Rs.2,00,000/- (iii) Addition of Rs.6,45,95,500/- comprising of Rs.1,65,66,500/-, Rs.4

DCIT14(1)(1), Mumbai vs. Offshore Marinetech Pvt. Ltd., Mumbai

In the result, appeal of the Revenue is dismissed

ITA 5307/MUM/2024[2010-11]Status: DisposedITAT Mumbai27 Nov 2024AY 2010-11

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 271(1)(c)

Assessing Officer levied penalty under section 271(1)(c) of the Act on estimate basis without any evidence on record with regard to concealment of income. Penalty under section 271(1)(c) of the Act is leviable to be imposed only where the assessee has concealed its particulars of income ... been sustained by applying adhoc GP rate, it cannot be said that it is a case of furnishing inaccurate particulars of income or concealment of income and accordingly, the order of the ld. CIT (A) deleting the penalty is upheld and consequently the grounds raised by the Revenue are dismissed

DCIT-CC-4(2), Mumbai vs. Shahrukh Khan, Mumbai

In the result, appeal filed by the revenue is dismissed

ITA 490/MUM/2024[2012-13]Status: DisposedITAT Mumbai27 Nov 2024AY 2012-13

Bench: Shri B R Baskaran & Shri Raj Kumar Chauhan

Section 143(2)Section 14ASection 250Section 271(1)(c)

Therefore, the penalty proceedings were initiated u/s 271(1)(c) of the Act for furnishing inaccurate particulars of income and concealment of income. 3. Vide order dated 30.03.2018 passed u/s 271(1)(c) of the Act, the AO did not levy any penalty on account of disallowance ... above discussions and observations, we are of the considered opinion that the revenue has failed to satisfy that there was deliberate concealment of income or furnishing of inaccurate particulars of income by the assessee. Therefore, we confirm the order of Ld. CIT (A) and find no illegality in appreciation

Nirmal M. Mulchandani, Mumbai vs. Income Tax Officer-25(1)(4), Mumbai

In the result, the appeal of the assessee is allowed for statistical purpose

ITA 4388/MUM/2023[2009-10]Status: DisposedITAT Mumbai27 Nov 2024AY 2009-10

Bench: Shri Narender Kumar Choudhry & Smt. Renu Jauhrinirmal M. Mulchandani V/S. Ito 25(1)(4), Mumbai 303, Vrajdeep, बनाम 220, 2Nd Floor, Kautilya Chandawarka, R. Road, Bhavan, Bkc, Eksar, Bandra(East), Mumbai-400092 Mumbai-400051 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aflpmo757K Appellant/अपीलार्थी Respondent/प्रतिवादी ..

For Appellant: Shri Vijay ShahFor Respondent: Shri Laxmi Kant
Section 143(3)Section 250Section 271(1)(c)

Mulchandani expenses. While he has accepted the addition for lack of inability to submit the evidence it cannot be taken that intentional concealment of income or furnishing of inaccurate particulars. The additions on account of interest paid towards interest earned is also not an addition which qualifies as concealment ... income. Similarly, addition on account of disallowance of interest paid is also not an addition which is liable to be treated as concealment of income. Thus, on both these grounds, Ld. CIT(A) has allowed relief to the assessee. The penalty has been confirmed only to the extent of addition

Nesco Limited, Mumbai vs. Assistant Commissioner of Income Tax Circle 13(1)(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 5182/MUM/2024[2016-17]Status: DisposedITAT Mumbai26 Nov 2024AY 2016-17

Bench: Shri Narender Kumar Choudhry & Shri Girish Agrawalassessment Year: 2016-17

For Appellant: Shri Satish R. Mody, AdvocateFor Respondent: Shri Preetam Kumar Turerao, Sr. AR
Section 143(3)Section 271(1)(c)Section 36(1)(vii)Section 36(2)(i)

years. Ld. 4 Nesco Ltd., AY 2016-17 Assessing Officer completed the penalty proceedings by imposing minimum penalty of Rs.4,08,100/- for concealment of income. Aggrieved, assessee went in appeal before the ld. CIT(A). 5. It was contended by the assessee that ld. Assessing Officer had never doubted

Late Davinder Kumar, New Delhi vs. DCIT, New Delhi

In the result, the appeal of the assessee in ITA No

ITA 2055/DEL/2016[2007-08]Status: DisposedITAT Delhi26 Nov 2024AY 2007-08

Bench: Shri Mahavir Singh & Shri Naveen Chandra

For Appellant: Shri Neelkant Khandelwal, AdvFor Respondent: Shri Dayainder Singh Sidhu, CIT-DR
Section 132(4)Section 153ASection 271Section 271(1)(c)Section 274

view that when the assessee has not been specifically made aware of the charges leveled against him as to whether there is a concealment of income or furnishing of inaccurate particulars of income on his part, the penalty u/s 271(1)(c) of the Act is not sustainable

Sri. Basavana Mathikere Betaswamy Gowda Ramaswamy Gowda, Bangalore vs. Income Tax Officer, Ward-2(2)(2), Bangalore

In the result, the appeal of the assessee is hereby partly allowed

ITA 1313/BANG/2024[2009-10]Status: DisposedITAT Bangalore25 Nov 2024AY 2009-10

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2009-10

For Appellant: Ms. Sunaina Bhatia, AdvocateFor Respondent: Shri V Parithivel, JCIT (DR)
Section 271(1)(C)Section 271(1)(c)Section 274

charge in the notice issued u/s 274 of the Act nor in the assessment order dated 30/12/2011, whether the penalty was levied for concealment of income or on account of furnishing of inaccurate particulars of income. Accordingly, the ld. AR contended that the penalty levied ... perused the materials available on record. The penalty u/s 271(1)(c) of the Act can be levied either on account of concealment of income or furnishing of inaccurate particulars of income. As such in the absence of any specific charge for initiation of penalty

Man Equipment Co. P.Ltd, Mumbai vs. DCIT Cen Cir 37, Mumbai

In the result, the appeal filed by the assessee is dismissed

ITA 5144/MUM/2015[2008-09]Status: DisposedITAT Mumbai25 Nov 2024AY 2008-09

Bench: Shri Narender Kumar Choudhry & Smt. Renu Jauhrim/S. Man Equipment Co. V/S. Dcit, Central Circle-37 Pvt. Ltd. बनाम Mumbai 69, Svp Road, Dongri, Mumbai-400009 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaacm9716E Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: NoneFor Respondent: Shri. B. Laxmi Kanth
Section 132Section 132(4)Section 143(3)Section 153ASection 250Section 271(1)Section 271(1)(c)Section 276C

assessing the total income at Rs. 1,48,28,031/- and penalty proceedings u/s 271(1)(c) were also initiated for the concealment of income. During the appellate proceedings, the assessee contended that the additional income of Rs. 1,00,00,000/- had been declared to avoid penalty and litigation ... peace of mind. Accordingly, there is neither concealment of income nor detection of undisclosed income during the course of assessment proceedings. However, Ld. AO invoked the provisions of Explanation 5A below P a g e | 3 A.Y. 2008-09 Man Equipment Co. P. Ltd. section

Rambadal Dhunmum Yadav, Vadodara vs. The Income Tax Officer, Ward-1(2)(5), Vadodara

In the result, the appeal of the assessee is partly allowed for statistical purposes

ITA 680/AHD/2024[2010-11]Status: DisposedITAT Ahmedabad22 Nov 2024AY 2010-11

Bench: Finally Considering The Appeal As Time Barred.

For Appellant: Adjournment ApplicationFor Respondent: Shri C. Dharani Nath, Sr. D.R
Section 143(3)Section 24Section 249Section 271(1)Section 271(1)(c)Section 68

unaccounted receipts received from various companies. The penalty proceedings u/s. 271(1)(c) of the Act was initiated to deal with the concealment of income of Rs. 48,02,102/-. The Assessing Officer subsequently imposed the penalty u/s. 271(1)(c) of Rs. 14,83,850/- on concealed income

Dineshbhai Muljibhai Patel, Vadodara vs. The Dy. Commissioner of Income Tax, Circle-1(1)(1) (Previously DCIT, Circle-1(3)), Vadodara

In the result, the appeal of the assessee is allowed

ITA 307/AHD/2024[2015-16]Status: DisposedITAT Ahmedabad22 Nov 2024AY 2015-16

Bench: Dr. Brr Kumarms. Suchitra Kamble

For Appellant: Shri Parimalsinh B. Parmar, ARFor Respondent: Shri C. Dharani Nath, Sr.DR
Section 131Section 143(3)Section 194CSection 234ASection 250Section 271(1)(c)

Penalty proceedings Dineshbhai Muljibhai Patel vs. DCIT Asst. Year : 2015-16 u/s.271(1)(c) of the Act are also initiated separately for concealment of income of Rs.3,33,558/-. 4. We have heard both the parties and perused the material available on record. We find that the addition has been

ACIT-3(4), Mumbai vs. Reliance Industries Limited, Mumbai

In the result, the appeal of the Revenue is dismissed whereas the appeal of the assessee is allowed

ITA 2898/MUM/2024[2016-17]Status: DisposedITAT Mumbai22 Nov 2024AY 2016-17

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2016-17 Reliance Industries Ltd., Dy. Cit Circle 3(4), 3Rd Floor, Maker Chamber Iv 222 Room No. 559, Aayakar Bhavan, Nariman Point, Vs. Maharshi Karve Road, Mumbai-400021. Mumbai-400020. Pan No. Aaacr 5055 K Appellant Respondent Assessment Year: 2016-17 Acit-3(4), Reliance Industries Ltd., Room No. 481(2), 4Th Floor, 3Rd Floor, Maker Chamber Iv Aayakar Bhavan, N.M. Road, Vs. Nariman Point, New Marine Lines, Mumbai-400021. Mumbai-400020. Pan No. Aaacr 5055 K Appellant Respondent

For Respondent: Mr. Madhur Agrawal
Section 14ASection 271(1)(c)Section 32A

despite the show cause notice dated 25.03.2019 did not strike off either of the limb as to whether penalty proceedings are initiated for concealment of income or for furnishing of inaccurate particulars of income. Penalty order passed is bad in law and void ab initio 3. erred in confirming ... levy of penalty, without appreciating that there was no satisfaction reached in the course of assessment proceeding about any concealment of income or furnishing of any inaccurate particulars of such income. Assessed income is less than returned income 4. Erred in confirming the levy of penalty, even though the assessed

Reliance Industries Limited, Mumbai vs. Deputy Commissioner of Income Tax -Circle 3(4), Mumbai

ITA 2767/MUM/2024[2016-17]Status: DisposedITAT Mumbai22 Nov 2024AY 2016-17

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

For Appellant: Mr. Madhur AgrawalFor Respondent: Ms. Sanyogita Nagpal, CIT-DR
Section 14ASection 271(1)(c)Section 32A

despite the show cause notice dated 25.03.2019 did not strike off either of the limb as to whether penalty proceedings are initiated for concealment of income or for furnishing of inaccurate particulars of income. Penalty order passed is bad in law and void ab initio 3. erred in confirming ... levy of penalty, without appreciating that there was no satisfaction reached in the course of assessment proceeding about any concealment of income or furnishing of any inaccurate particulars of such income. Assessed income is less than returned income 4. Erred in confirming the levy of penalty, even though the assessed

Palladam Krishnasamy Ganeshwar, Tirupur vs. DCIT, CC-3, Coimbatore

The appeal stand allowed

ITA 1221/CHNY/2024[2013-14]Status: DisposedITAT Chennai19 Nov 2024AY 2013-14

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.1221/Chny/2024 (िनधा9रणवष9 / Assessment Year: 2013-14) Shri Palladam Krishnasamy Ganeshwar Dcit बनाम/ 21, Shri Ganesa Textiles, Pollachi Road, Central Circle-3 Vs. Palladam, Tirupur-641 664. Coimbatore. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adfpg-6476-N (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ" कीओर से/ Appellant By : Shri S. Sridhar (Advocate)-Ld.Ar " थ" की ओर से/Respondent By : Shri R. Clement Ramesh Kumar (Cit)-Ld. Dr सुनवाई की तारीख/Date Of Hearing : 10-09-2024 घोषणा की तारीख /Date Of Pronouncement : 19-11-2024 आदेश / O R D E R Manoj Kumar Aggarwal ()

For Appellant: Shri S. Sridhar (Advocate)-Ld.ARFor Respondent: Shri R. Clement Ramesh Kumar (CIT)-Ld. DR
Section 132Section 132ASection 139Section 139(1)Section 143(3)Section 153ASection 153A(1)Section 271(1)(c)

cash paid by the assessee for purchase of land from certain parties. The Ld. AO accepted the same but initiated impugned penalty for concealment of income. 3. In response to penalty show cause notice, the assessee submitted that no penalty could be levied if any income is voluntarily admitted ... Taxmann.com 96). The assessee submitted that mere rejection of the explanation as offered by the assessee would not tantamount to presumption of concealment of income. However, Ld. AO rejected the same in terms of Explanation-5A to Sec. 271(1)(c) which provide that such admission would be deemed concealment

Mr. Madan Mohan Mishra, Mumbai vs. Income Tax Officer 10(3)(3), Mumbai

ITA 4175/MUM/2024[2009-10]Status: DisposedITAT Mumbai19 Nov 2024AY 2009-10

Bench: Smt. Beena Pillai

For Respondent: Shri Kiran Unavekar (Sr. DR)
Section 143(3)Section 15Section 271Section 271(1)(c)Section 68

facts on the file in, as much as, he was not justified to impose a penalty of Rs. 6,08,625/- for alleged concealment of income / furnishing inaccurate particulars of income without clearing specifying the limb of section 271(c) of the Act, under which the penalty proceedings has been

R.V.Raajah, Chennai vs. CIT(Appeals)-18, Chennai

The appeal stand allowed in terms of our above order

ITA 115/CHNY/2021[2012-13]Status: DisposedITAT Chennai18 Nov 2024AY 2012-13

Bench: Hon’Ble Shri Mahavir Singh, Vp & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.115/Chny/2021 (िनधा"रण वष" / Assessment Year: 2012-13) Shri R.V.Raajah Acit बनाम/ #97/2A, Harini Avenue, Central Circle-3(2) Velachery Main Road, Chennai. Vs. Guindy, Chennai-600 032. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adnpr-4751-R (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri R. Subramanian (Ca) - Ld. Ar ""थ"कीओरसे/Respondent By : Ms.R. Anita (Addl.Cit) - Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 29-08-2024 घोषणाकीतारीख /Date Of Pronouncement : 18-11-2024 आदेश / O R D E R Manoj Kumar Aggarwal ()

For Appellant: Shri R. Subramanian (CA) - Ld. ARFor Respondent: Ms.R. Anita (Addl.CIT) - Ld. Sr. DR
Section 132(4)Section 153ASection 271(1)(c)

various grounds and relied on various judicial decisions, Ld. CIT(A) rejected the same and levied impugned penalty of Rs.30.88 Lacs for concealment of income vide impugned order dated 24-03-2021. Aggrieved, the assessee is in further appeal before us. Our findings and Adjudication 3. The Ld. AR stated ... satisfied that the assessee had committed the default. In the case of the assessee, Ld. AO had recorded the satisfaction of concealment of income in the assessment order and it would be Ld. AO only who would be within its jurisdiction to levy the penalty. In assessee’s case

Sudesh Gupta, New Delhi vs. ACIT, Circle- 5(1), New Delhi

In the result, the Appeal filed by the Assessee stands allowed

ITA 284/DEL/2020[2013-14]Status: DisposedITAT Delhi18 Nov 2024AY 2013-14

Bench: Shri Shamim Yahya & Shri Yogesh Kumar Usa.Yr. : 2013-14 Sudesh Gupta, Vs. Acit, Circle 5(1), B-15, Kalindi Colony, Opp. Room No. G-15-B, C.R. Maharani Bagh, Building, New Delhi – 2 New Delhi (Pan: Aahpg5645G) (Appellant) (Respondent)

For Appellant: Ms. Ananya Kapoor, Adv. & ShriFor Respondent: Shri Piyush Tripathi, Sr. DR
Section 143(3)Section 147Section 148Section 2(22)Section 2(22)(e)Section 271Section 271(1)Section 271(1)(c)Section 274Section 275(1)(a)

same advance u/s 2(22)(e) of the IT Act and how the same can be amounted to furnishing of inaccurate particulars or concealment of income. iii) That the Ld. AO has initiated the penalty proceedings u/s 271(l)(c) of the I.T. Act, 1961 separately in the assessment order

ACIT-2(1)(1), Kanpur vs. Up State Yarn Company Limited, Kanpur

In the result, the appeal of Revenue is dismissed

ITA 469/LKW/2024[2009-10]Status: DisposedITAT Lucknow13 Nov 2024AY 2009-10

Bench: Shri Kul Bharat & Shri Anadee Nath Misshraacit-2(1)(1) Up State Yarn Company V. 15/295-A, Civil Lines, Kanpur, Limited Uttar Pradesh-208001. 1 Smith Square, 14/72, Civil Lines, Uttar Pradesh- 208001. Pan:Aaacu1674K (Appellant) (Respondent) Appellant By: Shri P. K. Kapoor, C.A. Respondent By: Shri Sanjeev Krishna Sharma, Addl Cit(Dr) Date Of Hearing: 11 11 2024 Date Of Pronouncement: 13 11 2024 O R D E R

For Appellant: Shri P. K. Kapoor, C.AFor Respondent: Shri Sanjeev Krishna Sharma, Addl
Section 254Section 271(1)(c)Section 40

income of the assessee. Secondly, the assessee must have furnished inaccurate particulars of his income. Present is not the case of concealment {he income. That is not the case of the Revenue either. However, the learned Counsel for revenue suggested that by making incorrect claim for the expenditure on interest ... inaccurate, the liability would arise. In Dilip N. Shroff v. Jt. CIT [2007] 6 SCC 329, this Court explained the terms: “concealment of income" and “furnishing inaccurate particulars" The Court went on to hold therein that in order to attract a penalty under section 271(1)(c) mens