Penalty for inaccurate particulars fails where disclosures were made, claims were bona fide, and no deliberate concealment was shown.

Penalty for furnishing inaccurate particulars under section 271(1)(c) requires proof that the return contained false or untrue details; a mere disallowance of a claim does not by itself justify penalty. Here, the section 14A adjustment was tax neutral under the tonnage tax scheme and the relevant facts were disclosed, the gratuity claim appeared in the tax audit report, the interest mismatch arose from reporting differences, and the capital gain error was an inadvertent mistake corrected during assessment. No deliberate concealment or misrepresentation was established, so deletion of penalty was justified.

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Issues: Whether penalty under section 271(1)(c) of the Income-tax Act, 1961 was leviable for additions relating to disallowance under section 14A, provision for gratuity, difference in interest reflected in Form 26AS, and wrong reporting of capital gain.

Analysis: Penalty for furnishing inaccurate particulars requires proof that the return contained details that were inaccurate, false, or not according to truth. A mere rejection of a claim does not by itself justify penalty. On the facts, the assessee was governed by the tonnage tax scheme, so the disallowance under section 14A was tax neutral and all relevant details had been disclosed. The gratuity claim had been reflected in the tax audit report, the interest difference arose from a mismatch between the assessee's accounting and the bank's reporting, and the capital gain error was an inadvertent mistake corrected during assessment. No deliberate concealment or misrepresentation was shown.

Conclusion: Penalty under section 271(1)(c) was not leviable and deletion of the penalty was justified.

Ratio Decidendi: Penalty for furnishing inaccurate particulars cannot be sustained where the claim is disallowed or found erroneous, but the relevant facts were disclosed and no deliberate concealment or false statement is established.

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