Unregistered exemption claim treated as inaccurate particulars, making penalty under the Income-tax Act sustainable.

Claiming exemption under section 11 without the requisite registration under section 12AA for the relevant assessment year rendered the claim untenable, and the filing of nil income on that basis was treated as furnishing inaccurate particulars. The assessee's reliance on bona fide claim authorities was found inapplicable on the facts. Penalty under section 271(1)(c) was therefore held leviable, the first appellate authority's deletion was set aside, and the penalty order of the Assessing Officer was restored.

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Issues: Whether penalty under section 271(1)(c) of the Income-tax Act, 1961 was exigible where the assessee claimed exemption under section 11 without having registration under section 12AA for the relevant assessment year.

Analysis: The assessee had returned nil income by claiming exemption under section 11, but the claim was rejected because registration under section 12AA was not available for the relevant year. On those facts, the claim of exemption was held to be untenable, and the conduct was treated as furnishing of inaccurate particulars. The authority relied on by the assessee on bona fide claim was found inapplicable to the present facts.

Conclusion: Penalty under section 271(1)(c) was held to be leviable, and the deletion of penalty by the first appellate authority was set aside.

Final Conclusion: The revenue's challenge succeeded, and the penalty order passed by the Assessing Officer was restored.

Ratio Decidendi: A claim of exemption made without the statutory registration required for the relevant assessment year can amount to furnishing inaccurate particulars and justify penalty under section 271(1)(c) of the Income-tax Act, 1961.

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