https://www.taxtmi.com/caselaws?id=208664 Penalty for concealment was held unwarranted where revised returns recharacterised securities income as business income on the strength of advance rulings and disclosed the factual and legal basis for that position. No material fact was found false or withheld, and the dispute turned on a difference of legal opinion over the correct head of income and treaty consequences. The mere failure of the claim in law did not establish concealment or furnishing of inaccurate particulars. The claim was treated as bona fide, and deletion of penalty under section 271(1)(c) was upheld. en-us Fri, 29 Apr 2011 00:00:00 +0530 Mon, 30 May 2011 11:58:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=208664 Penalty for concealment was held unwarranted where revised returns recharacterised securities income as business income on the strength of advance rulings and disclosed the factual and legal basis for that position. No material fact was found false or withheld, and the dispute turned on a difference of legal opinion over the correct head of income and treaty consequences. The mere failure of the claim in law did not establish concealment or furnishing of inaccurate particulars. The claim was treated as bona fide, and deletion of penalty under section 271(1)(c) was upheld. Case-Laws Income Tax Fri, 29 Apr 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=208664