Bona fide wrong tax claim does not trigger concealment penalty absent deliberate inaccurate particulars.

A bona fide but wrong claim for deduction, an incorrect capital gains computation, and a disputed land valuation did not, on these facts, justify penalty under section 271(1)(c) of the Income-tax Act, 1961. The claim for deduction under section 54B was made on the basis of a High Court decision, and the record did not show deliberate concealment or furnishing of inaccurate particulars. A mistaken or arguable claim, by itself, was insufficient for penalty; the operative point was the absence of intentional suppression, so penalty was not sustainable.

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Issues: Whether penalty under section 271(1)(c) of the Income-tax Act, 1961 was leviable for a wrong claim of deduction, incorrect computation of capital gains, and disputed valuation of land.

Analysis: The assessee's claim for deduction under section 54B, though ultimately rejected, was made on the basis of a High Court decision and was thus bona fide. The valuation of land was derived from competing estimates and sale instances, and the record did not show any finding that inaccurate particulars were deliberately furnished. A wrong claim or an incorrect computation, by itself, does not amount to concealment of income or furnishing of inaccurate particulars for penalty purposes. The circumstances showed at most an arguable or mistaken claim, not deliberate suppression.

Conclusion: Penalty under section 271(1)(c) was not sustainable; the assessee succeeded.

Ratio Decidendi: A bona fide wrong claim or incorrect computation, without deliberate concealment or furnishing of inaccurate particulars, does not attract penalty under section 271(1)(c) of the Income-tax Act, 1961.

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