https://www.taxtmi.com/caselaws?id=247346 Penalty under section 271(1)(c) was not leviable where the assessee had disclosed the material facts in the return and notes to accounts, and the Assessing Officer had taken cognizance of those disclosures. The dispute concerned the year in which capital gains on the land transfer became taxable, a question dependent on the memorandum of understanding and the point of transfer, and the matter was already the subject of quantum litigation. Because the assessee had later offered the capital gains in another assessment year and the issue was debatable, the addition reflected only a difference of opinion on tax incidence, not concealment or furnishing of inaccurate particulars. The penalty was deleted. en-us Wed, 30 Apr 2014 00:00:00 +0530 Fri, 09 May 2014 10:48:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=247346 Penalty under section 271(1)(c) was not leviable where the assessee had disclosed the material facts in the return and notes to accounts, and the Assessing Officer had taken cognizance of those disclosures. The dispute concerned the year in which capital gains on the land transfer became taxable, a question dependent on the memorandum of understanding and the point of transfer, and the matter was already the subject of quantum litigation. Because the assessee had later offered the capital gains in another assessment year and the issue was debatable, the addition reflected only a difference of opinion on tax incidence, not concealment or furnishing of inaccurate particulars. The penalty was deleted. Case-Laws Income Tax Wed, 30 Apr 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=247346