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The HC set aside ITAT's interpretation that stricter culpability standards are required for imposing penalty under s.271(1)(c). The court relied on Dharamendra Textile Processors, which established strict liability for concealment or inaccurate particulars in returns, clarifying that willful concealment is not essential for civil liability under s.271(1)(c), unlike prosecution under s.276-C. The HC distinguished this from Dilip N. Shroff, which was deemed incorrectly decided. Despite correcting the legal principle, the HC declined to interfere with ITAT's deletion of penalty in the specific case, as the amount was below Rs.5 lakhs and the assessee was an individual, thus partially affirming the ITAT order.
The HC set aside ITAT's interpretation that stricter culpability standards are required for imposing penalty under s.271(1)(c). The court relied on Dharamendra Textile Processors, which established strict liability for concealment or inaccurate particulars in returns, clarifying that willful concealment is not essential for civil liability under s.271(1)(c), unlike prosecution under s.276-C. The HC distinguished this from Dilip N. Shroff, which was deemed incorrectly decided. Despite correcting the legal principle, the HC declined to interfere with ITAT's deletion of penalty in the specific case, as the amount was below Rs.5 lakhs and the assessee was an individual, thus partially affirming the ITAT order.
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