https://www.taxtmi.com/caselaws?id=247697 Penalty under Section 271(1)(c) is not attracted where the assessee has disclosed all primary facts relating to purchase, sale, payment, receipt and resulting profit, and the dispute is only over the correct head of income. A mere change in characterisation of the disclosed income, or rejection of the assessee's legal claim, does not by itself amount to concealment or furnishing of inaccurate particulars. On these facts, the addition arose from the Assessing Officer's treatment of the transaction under a different head, not from suppression of the transaction itself, so the concealment penalty was deleted. en-us Fri, 09 May 2014 00:00:00 +0530 Tue, 20 May 2014 08:40:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=247697 Penalty under Section 271(1)(c) is not attracted where the assessee has disclosed all primary facts relating to purchase, sale, payment, receipt and resulting profit, and the dispute is only over the correct head of income. A mere change in characterisation of the disclosed income, or rejection of the assessee's legal claim, does not by itself amount to concealment or furnishing of inaccurate particulars. On these facts, the addition arose from the Assessing Officer's treatment of the transaction under a different head, not from suppression of the transaction itself, so the concealment penalty was deleted. Case-Laws Income Tax Fri, 09 May 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=247697