https://www.taxtmi.com/caselaws?id=215495 Penalty under section 271(1)(c) was not attracted where the assessee had disclosed all primary facts and the disputed claims were rejected only on a different view of allowability. The business loss disallowance was based on the expenditure being considered excessive, not bogus or false, and the interest claim failed on legal inadmissibility, including section 14A, without any finding of concealment or inaccurate particulars. As penalty proceedings are distinct from assessment proceedings, a bona fide but unsustainable claim does not by itself justify penalty. The penalty was therefore deleted. en-us Wed, 28 Mar 2012 00:00:00 +0530 Wed, 08 Aug 2012 18:21:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=215495 Penalty under section 271(1)(c) was not attracted where the assessee had disclosed all primary facts and the disputed claims were rejected only on a different view of allowability. The business loss disallowance was based on the expenditure being considered excessive, not bogus or false, and the interest claim failed on legal inadmissibility, including section 14A, without any finding of concealment or inaccurate particulars. As penalty proceedings are distinct from assessment proceedings, a bona fide but unsustainable claim does not by itself justify penalty. The penalty was therefore deleted. Case-Laws Income Tax Wed, 28 Mar 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=215495