Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
The ITAT held that the penalty under section 271(1)(c) for furnishing inaccurate particulars of income was not leviable as the assessee rectified the inadvertent erroneous claim of deduction under section 54F by filing a revised computation during assessment proceedings, demonstrating bona fide intent. The tribunal distinguished between concealment of income and furnishing inaccurate particulars, noting the AO initiated penalty proceedings for concealment but levied penalty for inaccurate particulars without proper satisfaction or notice under that limb. This procedural inconsistency rendered the penalty unsustainable. Consequently, the penalty imposed under section 271(1)(c) was deleted, and the assessee's appeal was allowed.
The ITAT held that the penalty under section 271(1)(c) for furnishing inaccurate particulars of income was not leviable as the assessee rectified the inadvertent erroneous claim of deduction under section 54F by filing a revised computation during assessment proceedings, demonstrating bona fide intent. The tribunal distinguished between concealment of income and furnishing inaccurate particulars, noting the AO initiated penalty proceedings for concealment but levied penalty for inaccurate particulars without proper satisfaction or notice under that limb. This procedural inconsistency rendered the penalty unsustainable. Consequently, the penalty imposed under section 271(1)(c) was deleted, and the assessee's appeal was allowed.
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