https://www.taxtmi.com/caselaws?id=121573 Penalty under section 271(1)(c) is attracted only on concealment of income or furnishing of inaccurate particulars, and Explanation 1 applies where the assessee fails to explain, gives a false explanation, or cannot substantiate a bona fide explanation despite full disclosure. A mere disallowance of a claim in assessment does not by itself establish concealment, because assessment and penalty proceedings are distinct. Where the assessee had disclosed all material facts and supporting particulars for project feasibility and market research expenditure, the dispute concerned only the allowability of the deduction and amounted to a debatable claim. On that basis, penalty was not sustainable. en-us Fri, 13 Feb 2009 00:00:00 +0530 Tue, 31 Jul 2012 16:58:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=121573 Penalty under section 271(1)(c) is attracted only on concealment of income or furnishing of inaccurate particulars, and Explanation 1 applies where the assessee fails to explain, gives a false explanation, or cannot substantiate a bona fide explanation despite full disclosure. A mere disallowance of a claim in assessment does not by itself establish concealment, because assessment and penalty proceedings are distinct. Where the assessee had disclosed all material facts and supporting particulars for project feasibility and market research expenditure, the dispute concerned only the allowability of the deduction and amounted to a debatable claim. On that basis, penalty was not sustainable. Case-Laws Income Tax Fri, 13 Feb 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=121573