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“penalty u/s 271(1)(c)”

PenaltySection 271(1)(c)Section 271(1)(c)2,277 judgments

The decision most relied on for penalty u/s 271(1)(c) is CIT v. Atul Mohan Bindal (9 SCC 589), cited in 200 judgments on BharatTax.

Leading authorities on penalty u/s 271(1)(c)

CIT v. Atul Mohan Bindal
9 SCC 589 · 2009 · Supreme Court
200
citing judgments

The Supreme Court clarifies the scope of penalty under Section 271(1)(c), holding that for its applicability, conditions stated in the provision must strictly exist, and making an incorrect claim in law does not automatically amount to furnishing inaccurate particulars of income.

CIT v. Subhash Trading Co. Ltd.
221 ITR 110 · 1996 · High Court
146
citing judgments

Penalty under Section 271(1)(c) of the Income Tax Act cannot be levied when an addition to income is based purely on an estimate, without concrete evidence proving concealment of income or furnishing of inaccurate particulars.

Prasanna Dugar v. CIT
70 Taxmann.com 175 · 2016 · Supreme Court
49
citing judgments

Penalty under section 271(1)(c) can be levied even if the assessee voluntarily discloses income after detection by the department or subsequent to a search, especially when the explanation provided is not bona fide or cannot be substantiated.

Ganga Iron & Steel Trading Co. v. Commissioner of Income Tax
135 Taxmann.com 244 · 2022 · High Court
45
citing judgments

A notice imposing penalty under section 271(1)(c) of the Income Tax Act is invalid if it shows non-application of mind by the Assessing Officer regarding the specific grounds for levying the penalty.

CIT v. Dhillon Rice Mills
256 ITR 447 · 2002 · High Court
30
citing judgments

Penalty under section 271(1)(c) is not leviable when additions to income are made on the basis of estimation, rather than on concrete evidence of concealment. Deletion of such a penalty is upheld.

ACIT v. Gebilal Kanhaialal HUF
348 ITR 561 · 2012 · Supreme Court
28
citing judgments

Section 271AAA penalty deletion can be based on the Apex Court's decision in ACIT v. Gebilal Kanhaialal HUF (2012) 348 ITR 561, particularly when there was no specific question put to the assessee about the manner of earning undisclosed income.

CIT v. Norton Electronics Systems (P) Ltd.
41 Taxmann.com 280 · 2014 · High Court
27
citing judgments

Penalty under Section 271(1)(c) is not sustainable when the income addition is made on an estimated basis without clinching material suggesting concealment or inaccurate particulars.

New Holland Tractors (India) (P.) Ltd. v. CIT
49 Taxmann.com 573 · 2014 · High Court
24
citing judgments

The charge of concealment of income and furnishing of inaccurate particulars of income may overlap. A taxpayer's conduct can be considered bonafide even if their submissions were rejected in the quantum appeal.

Judgments citing penalty u/s 271(1)(c)

Jaikishin Omprakash Pahuja, Ghatkopar, Mumbai vs. ITO Ward 2(2), Kalyan, Mumbai

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

ITA 8893/MUM/2025[2016-17]Status: DisposedITAT Mumbai05 Mar 2026AY 2016-17

Bench: Shri Saktijit Dey & Shri Makarand V Mahadeokar

Section 115BSection 142(1)Section 143(2)Section 144BSection 147Section 148Section 148ASection 250Section 69

circumstances of the case and in law, the AO erred in charging interest u/s 234A, B, C and D and initiating penalty u/s 271(1)(c), 271(1)(b) and 271F. 7. In the facts and circumstances of the case and in law, the learned Commissioner of Income

Deputy Commissioner of Income Tax, Circle-2 1 1, Vadodara vs. Unimed Technologies Limited, Panchmahal

In the result, the appeal filed by the Revenue is hereby dismissed

ITA 279/AHD/2026[2016-17]Status: DisposedITAT Ahmedabad03 Mar 2026AY 2016-17

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 143(3)Section 271Section 271(1)(c)Section 43A

show-cause notice dated 27.03.2025 and initiated penalty proceedings. The assessee filed a reply on 28.03.2025. However, the Ld AO levied penalty u/s. 271[1][c] of Rs.1,61,42,867/- vide order dated 29.03.20 for furnishing inaccurate particulars of income. 4. Aggrieved against the Penalty order, assessee company filed ... residual additions sustained in the quantum proceedings involve interpretative and debatable issues with full disclosure of facts by the appellant, no penalty u/s 271(1)(c) is leviable on such additions. Accordingly, the penalty of Rs.1,61,42,867/- levied u/s 271(1)(c) is deleted. 5.7. In the light

Sun Diam, Surat vs. ITO 2(3)(6), Surat

In the result, appeal of the assessee is allowed

ITA 1112/SRT/2025[2013-14]Status: DisposedITAT Surat27 Feb 2026AY 2013-14

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

For Appellant: Shri Himanshu Gandhi, CAFor Respondent: Shri Ajay Uke, Sr.DR
Section 271Section 271(1)(c)

date of hearing. 2. 1. On the facts and circumstances of the case and law, the Ld. CIT(A) erred in confirming penalty u/s 271(1)(c) of the Income Tax Act, 1961 on the basis of invalid penalty notice in which the limb of levy of penalty under section ... mentioned. 3. 2. On the facts and circumstances of the case and law, the d CIT(A) erred in confirming penalty u/s 271(1)(c) of the Income Tax Act, 1961 which is time barred and thus the penalty order is itself bad in law and required to be quashed

Sun Diam, Surat vs. ITO 2(3)(6), Surat

In the result, appeal of the assessee is allowed

ITA 1111/SRT/2025[2012-13]Status: DisposedITAT Surat27 Feb 2026AY 2012-13

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

For Appellant: Shri Himanshu Gandhi, CAFor Respondent: Shri Ajay Uke, Sr.DR
Section 271Section 271(1)(c)

date of hearing. 2. 1. On the facts and circumstances of the case and law, the Ld. CIT(A) erred in confirming penalty u/s 271(1)(c) of the Income Tax Act, 1961 on the basis of invalid penalty notice in which the limb of levy of penalty under section ... mentioned. 3. 2. On the facts and circumstances of the case and law, the d CIT(A) erred in confirming penalty u/s 271(1)(c) of the Income Tax Act, 1961 which is time barred and thus the penalty order is itself bad in law and required to be quashed

Sun Diam, Surat vs. ITO 2(3)(6), Surat

In the result, appeal of the assessee is allowed

ITA 1110/SRT/2025[2011-12]Status: DisposedITAT Surat27 Feb 2026AY 2011-12

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

For Appellant: Shri Himanshu Gandhi, CAFor Respondent: Shri Ajay Uke, Sr.DR
Section 271Section 271(1)(c)

date of hearing. 2. 1. On the facts and circumstances of the case and law, the Ld. CIT(A) erred in confirming penalty u/s 271(1)(c) of the Income Tax Act, 1961 on the basis of invalid penalty notice in which the limb of levy of penalty under section ... mentioned. 3. 2. On the facts and circumstances of the case and law, the d CIT(A) erred in confirming penalty u/s 271(1)(c) of the Income Tax Act, 1961 which is time barred and thus the penalty order is itself bad in law and required to be quashed

Sun Diam, Surat vs. ITO 2(3)(6), Surat

In the result, appeal of the assessee is allowed

ITA 1109/SRT/2025[2010-11]Status: DisposedITAT Surat27 Feb 2026AY 2010-11

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

For Appellant: Shri Himanshu Gandhi, CAFor Respondent: Shri Ajay Uke, Sr.DR
Section 271Section 271(1)(c)

date of hearing. 2. 1. On the facts and circumstances of the case and law, the Ld. CIT(A) erred in confirming penalty u/s 271(1)(c) of the Income Tax Act, 1961 on the basis of invalid penalty notice in which the limb of levy of penalty under section ... mentioned. 3. 2. On the facts and circumstances of the case and law, the d CIT(A) erred in confirming penalty u/s 271(1)(c) of the Income Tax Act, 1961 which is time barred and thus the penalty order is itself bad in law and required to be quashed

Sun Diam, Surat vs. ITO 2(3)(6), Surat

In the result, appeal of the assessee is allowed

ITA 1108/SRT/2025[2009-10]Status: DisposedITAT Surat27 Feb 2026AY 2009-10

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

For Appellant: Shri Himanshu Gandhi, CAFor Respondent: Shri Ajay Uke, Sr.DR
Section 271Section 271(1)(c)

date of hearing. 2. 1. On the facts and circumstances of the case and law, the Ld. CIT(A) erred in confirming penalty u/s 271(1)(c) of the Income Tax Act, 1961 on the basis of invalid penalty notice in which the limb of levy of penalty under section ... mentioned. 3. 2. On the facts and circumstances of the case and law, the d CIT(A) erred in confirming penalty u/s 271(1)(c) of the Income Tax Act, 1961 which is time barred and thus the penalty order is itself bad in law and required to be quashed

Sun Diam, Surat vs. ITO 2(3)(6), Surat

In the result, appeal of the assessee is allowed

ITA 1107/SRT/2025[2008-09]Status: DisposedITAT Surat27 Feb 2026AY 2008-09

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

For Appellant: Shri Himanshu Gandhi, CAFor Respondent: Shri Ajay Uke, Sr.DR
Section 271Section 271(1)(c)

date of hearing. 2. 1. On the facts and circumstances of the case and law, the Ld. CIT(A) erred in confirming penalty u/s 271(1)(c) of the Income Tax Act, 1961 on the basis of invalid penalty notice in which the limb of levy of penalty under section ... mentioned. 3. 2. On the facts and circumstances of the case and law, the d CIT(A) erred in confirming penalty u/s 271(1)(c) of the Income Tax Act, 1961 which is time barred and thus the penalty order is itself bad in law and required to be quashed

Mummalaneni Raghavan, Guntur vs. Income Tax Officer, Guntur

In the result, both the appeals of the assessee are allowed

ITA 628/VIZ/2025[2016-17]Status: DisposedITAT Visakhapatnam27 Feb 2026AY 2016-17

Bench: Itat, Stating That The Reopening Of Assessment U/S 147 Of The Act Was Based Merely On System Generated Information, Which Is Invalid & Without Any Tangible Material. In The Grounds Of Appeal, It Was Mentioned That The Assessment U/S 147 Is Beyond Time Limit Prescribed & Hence, The

Section 144Section 144BSection 147Section 194ASection 56

addition made by the Ld.AO in the assessment order, which was confirmed by the Ld.CIT(A), the L\d.AO levied penalty u/s 271(1)(c), stating that the value mentioned in the Joint Development Agreement is the income of the appellant. Since the addition itself is deleted, the consequent penalty

Mummalaneni Raghavan, Guntur vs. Income Tax Officer, Ward-2(1), Guntur

In the result, both the appeals of the assessee are allowed

ITA 627/VIZ/2025[2016-17]Status: DisposedITAT Visakhapatnam27 Feb 2026AY 2016-17

Bench: Itat, Stating That The Reopening Of Assessment U/S 147 Of The Act Was Based Merely On System Generated Information, Which Is Invalid & Without Any Tangible Material. In The Grounds Of Appeal, It Was Mentioned That The Assessment U/S 147 Is Beyond Time Limit Prescribed & Hence, The Proceedings Are Void-Ab-Initio.

Section 144Section 144BSection 147Section 194ASection 56

Based on the addition made by the Ld.AO in the assessment order, which was confirmed by the Ld.CIT(A), the Ld.AO levied penalty u/s 271(1)(c), stating that the value mentioned in the Joint Development Agreement is the income of the appellant. Since the addition itself is deleted

M/S Pumarth Infrastructure Private Limited, Indore vs. The Asstt Commissioner of Income Tax Circle - 4(1), Aaykar Bhawan, Indore

Appeals are allowed for statistical purposes

ITA 766/IND/2024[2009 -2010]Status: DisposedITAT Indore27 Feb 2026

Bench: Shri B.M. Biyani & Shri Paresh M. Joshi

Section 132Section 153ASection 271(1)(c)Section 40A(3)

relief to assessee. (iv) Simultaneous with passing of assessment-order dated 29.01.2016 as aforesaid, the AO also initiated proceedings for imposition of penalties u/s 271(1)(c) and issued show-cause notices to assessee. However, the AO kept penalty proceedings in abeyance till the quantum- proceedings were pending before ITAT ... amounting to Rs. 12,74,144/- for AY 2011-12. For these sustained additions, the AO imposed impugned penalties u/s 271(1)(c). 4. Originally, the assessee raised grounds in Form No. 36. Since these grounds are identical in all three years, we re-produce below the grounds of first

M/S Pumarth Infrastructure Private Limited, Indore vs. The Asstt Commissioner of Income Tax Circle 4(1), Aaykar Bhawan, Indore

Appeals are allowed for statistical purposes

ITA 765/IND/2024[2011-12]Status: DisposedITAT Indore27 Feb 2026AY 2011-12
Section 132Section 153ASection 250Section 271(1)(c)Section 40A(3)

relief to assessee. (iv) Simultaneous with passing of assessment-order dated 29.01.2016 as aforesaid, the AO also initiated proceedings for imposition of penalties u/s 271(1)(c) and issued show-cause notices to assessee. However, the AO kept penalty proceedings in abeyance till the quantum- proceedings were pending before ITAT ... amounting to Rs. 12,74,144/- for AY 2011-12. For these sustained additions, the AO imposed impugned penalties u/s 271(1)(c). 4. Originally, the assessee raised grounds in Form No. 36. Since these grounds are identical in all three years, we re-produce below the grounds of first

M/S Pumarth Infrastructure, Indore vs. The Asst Commissioner If Income Tax Circle 4(1), Aaykar Bhawan, Indore

Appeals are allowed for statistical purposes

ITA 757/IND/2024[2010 -11]Status: DisposedITAT Indore27 Feb 2026

Bench: Shri B.M. Biyani & Shri Paresh M. Joshi

Section 132Section 153ASection 271(1)(c)Section 40A(3)

relief to assessee. (iv) Simultaneous with passing of assessment-order dated 29.01.2016 as aforesaid, the AO also initiated proceedings for imposition of penalties u/s 271(1)(c) and issued show-cause notices to assessee. However, the AO kept penalty proceedings in abeyance till the quantum- proceedings were pending before ITAT ... amounting to Rs. 12,74,144/- for AY 2011-12. For these sustained additions, the AO imposed impugned penalties u/s 271(1)(c). 4. Originally, the assessee raised grounds in Form No. 36. Since these grounds are identical in all three years, we re-produce below the grounds of first

Kapil Khandelwal, Bareilly, Uttar Pradesh vs. Asst. Commissioner of Income Tax, Circle-I, Bareilly, Uttar Pradesh

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

ITA 335/LKW/2025[2015-16]Status: DisposedITAT Lucknow27 Feb 2026AY 2015-16

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharya.Y. 2015-16 Kapil Khandelwal, Vs. Asstt. Commissioner Of 56, Moar Kothi, Gangapur, Bareilly Income Tax, Circle-I, Bareilly Pan: Aiypk4908M (Appellant) (Respondent) Assessee By: Sh. P.K. Kapoor, C.A. Revenue By: Sh. R.R.N. Shukla, Addl Cit Dr Date Of Hearing: 22.01.2026 Date Of Pronouncement: 27.02.2026 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed By The Assessee Against The Orders Of The Ld. Cit(A), Nfac Under Section 250 Of The Income Tax Act, 1961, Wherein The Ld. Cit(A) Has Confirmed The Penalty Levied Upon The Assessee Under Section 271(1)(C) By The Ld. Ao On 17.03.2022 & Dismissed The Appeal Of The Assessee For The A.Y. 2015-16. The Grounds Of Appeal Are As Under: - “1. Because Requisite Satisfaction For Levy Of Penalty U/S 271(1)(C) If The Income Tax Act 1961 Was Not Recorded In The Regular Assessment Order Dated 22.12.2017 Passed A/S 100%, Therefore, Penalty Proceedings Got Wholly Vitiated & Consequently, The Id. "Cit(A)" Ought To Have Quashed The Penalty Order Dated 17.03.2022, Being Illegal, Bad-In-Law & Without Jurisdiction 2. Because The Show Cause Notice For Levy Of Penalty Under Section 271(1)(C) Of The Act Did Not Specify Under Which Limb Penalty Was Sought To Be Imposed I.E.. Whether On Account Of Concealment Of Income Or For Furnishing Inaccurate Particulars Of Income & Consequently, The Penalty Order Dated 17.03.2022 Passed By Faceless Assessing Officer Deserved To Be Quashed.

For Appellant: Sh. P.K. Kapoor, C.AFor Respondent: Sh. R.R.N. Shukla, Addl CIT DR
Section 10(38)Section 250Section 271(1)(c)

assessee for the A.Y. 2015-16. The grounds of appeal are as under: - “1. BECAUSE requisite satisfaction for levy of penalty u/s 271(1)(c) if the Income Tax Act 1961 was not recorded in the regular assessment order dated 22.12.2017 passed a/s 100%, therefore, penalty proceedings got wholly vitiated

Health Biotech Limited, Chandigarh vs. Deputy Commissioner of Income Tax, Circle 1(1), Chandigarh

In the result, the appeal of the assessee is allowed

ITA 987/CHANDI/2025[2014-15]Status: DisposedITAT Chandigarh24 Feb 2026AY 2014-15

Bench: the disposal of the same.

For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR
Section 143(3)Section 271(1)(c)Section 274Section 40

circumstances and legal position of the case, Worthy CIT(A) has erred in confirming the action of Ld. AO of imposition of penalty u/s 271(1)(c) of Rs. 69,68,581/- on alleged furnishing of inaccurate particulars of income added by Ld. AO of Rs.2 ... circumstances and legal position of the case, Worthy CIT(A) has erred in confirming the action of Ld. AO of imposition of penalty u/s 271(1)(c) of Rs. 69,68,581/- on account of disallowance u/s 40(a)(ia) of Rs. 2,23,34,758/-. 4. That on facts

DCIT, Circle-1, Ranchi vs. Central Coalfield Ltd, Ranchi

In the result, appeal of the assessee is allowed and the appeal of the revenue is dismissed

ITA 223/RAN/2024[2013-14]Status: DisposedITAT Ranchi20 Feb 2026AY 2013-14

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahaym/S Central Coalfields Ltd., D.C.I.T., Darbhanga House, Kutchery Road, Circle-1, Vs. Ranchi-834001 (Jharkhand) Ranchi. Pan No. Aaacc 7476 R Appellant/ Assessee Respondent/ Revenue D.C.I.T., Central Coalfield Ltd., Circle-1, 4Th Floor, Central Revenue Building Vs. Ranchi. Annexee, 5A, Main Road, Ranchi-834001 (Jharkhand) Pan No. Aaacc 7476 R Appellant/ Revenue Respondent/ Assessee

Section 271Section 271(1)(c)Section 274Section 40

penalty imposed only on additions/ disallowance of expenses on difference of opinion is unjustified, arbitrary and illegal. 5. For that the penalty u/s 271(1)(c) as imposed by AO & sustained by CIT (A) on disallowances of Land & Crop Compensation & CSR Expenses as under, on account of furnishing of inaccurate

DCIT, Circle-1, Ranchi vs. Central Coalfields Limited, Ranchi

In the result, appeal of the assessee is allowed and the appeal of the revenue is dismissed

ITA 220/RAN/2024[2012-13]Status: DisposedITAT Ranchi20 Feb 2026AY 2012-13

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahaym/S Central Coalfields Ltd., D.C.I.T., Darbhanga House, Kutchery Road, Circle-1, Vs. Ranchi-834001 (Jharkhand) Ranchi. Pan No. Aaacc 7476 R Appellant/ Assessee Respondent/ Revenue D.C.I.T., Central Coalfield Ltd., Circle-1, 4Th Floor, Central Revenue Building Vs. Ranchi. Annexee, 5A, Main Road, Ranchi-834001 (Jharkhand) Pan No. Aaacc 7476 R Appellant/ Revenue Respondent/ Assessee

Section 271Section 271(1)(c)Section 274Section 32

penalty imposed only on additions/ disallowance of expenses on difference of opinion is unjustified, arbitrary and illegal. 5. For that the penalty u/s 271(1)(c) as imposed by AO & sustained by CIT (A) on disallowances of following expenses on account of furnishing of inaccurate particulars. However, in the penalty

DCIT, Circle-1, Ranchi vs. Central Coalfield Ltd, Ranchi

In the result, appeal of the assessee is allowed and the appeal of the revenue is dismissed

ITA 218/RAN/2024[2011-12]Status: DisposedITAT Ranchi20 Feb 2026AY 2011-12

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahaym/S Central Coalfields Ltd., D.C.I.T., Darbhanga House, Kutchery Road, Circle-1, Vs. Ranchi-834001 (Jharkhand) Ranchi. Pan No. Aaacc 7476 R Appellant/ Assessee Respondent/ Revenue D.C.I.T., Central Coalfield Ltd., Circle-1, 4Th Floor, Central Revenue Building Vs. Ranchi. Annexee, 5A, Main Road, Ranchi-834001 (Jharkhand) Pan No. Aaacc 7476 R Appellant/ Revenue Respondent/ Assessee

Section 271Section 271(1)(c)Section 274

penalty imposed only on additions/ disallowance of expenses on difference of opinion is unjustified, arbitrary and illegal. 5. For that the penalty u/s 271(1)(c) as imposed by AO & sustained by CIT (A) on disallowances of following expenses on account of furnishing of inaccurate particulars. However, in the penalty

DCIT, Circle-1, Ranchi vs. Central Coalfields Ltd, Ranchi

In the result, appeal of the assessee is allowed and the appeal of the revenue is dismissed

ITA 217/RAN/2024[2010-11]Status: DisposedITAT Ranchi20 Feb 2026AY 2010-11

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahaym/S Central Coalfields Ltd., D.C.I.T., Darbhanga House, Kutchery Road, Circle-1, Vs. Ranchi-834001 (Jharkhand) Ranchi. Pan No. Aaacc 7476 R Appellant/ Assessee Respondent/ Revenue D.C.I.T., Central Coalfield Ltd., Circle-1, 4Th Floor, Central Revenue Building Vs. Ranchi. Annexee, 5A, Main Road, Ranchi-834001 (Jharkhand) Pan No. Aaacc 7476 R Appellant/ Revenue Respondent/ Assessee

Section 271Section 271(1)(c)Section 274Section 40

penalty imposed only on additions/ disallowance of expenses on difference of opinion is unjustified, arbitrary and illegal. 5. For that the penalty u/s 271(1)(c) as imposed by AO & sustained by CIT (A) on disallowances of Land & Crop compensation as under, on account of furnishing of inaccurate particulars. However

M/S. Central Coalfields Ltd., Ranchi vs. DCIT Circle-1, Ranchi

In the result, appeal of the assessee is allowed and the appeal of the revenue is dismissed

ITA 213/RAN/2024[2013-14]Status: DisposedITAT Ranchi20 Feb 2026AY 2013-14

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahaym/S Central Coalfields Ltd., D.C.I.T., Darbhanga House, Kutchery Road, Circle-1, Vs. Ranchi-834001 (Jharkhand) Ranchi. Pan No. Aaacc 7476 R Appellant/ Assessee Respondent/ Revenue D.C.I.T., Central Coalfield Ltd., Circle-1, 4Th Floor, Central Revenue Building Vs. Ranchi. Annexee, 5A, Main Road, Ranchi-834001 (Jharkhand) Pan No. Aaacc 7476 R Appellant/ Revenue Respondent/ Assessee

Section 271Section 271(1)(c)Section 274Section 40

penalty imposed only on additions/ disallowance of expenses on difference of opinion is unjustified, arbitrary and illegal. 5. For that the penalty u/s 271(1)(c) as imposed by AO & sustained by CIT (A) on disallowances of Land & Crop Compensation & CSR Expenses as under, on account of furnishing of inaccurate