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    <description>Full disclosure of primary facts in audited accounts, notes, the tax audit report and computation supported the assessee&#039;s claim that the waiver amount was a capital receipt. The issue was treated as a debatable question of law, and the Court applied the settled principle that penalty under section 271(1)(c) cannot be imposed merely because a legal claim is rejected. Because the explanation was found bona fide and not shown to be false, an incorrect claim in law did not amount to concealment or furnishing inaccurate particulars, and the penalty was deleted.</description>
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      <link>https://www.taxtmi.com/caselaws?id=253536</link>
      <description>Full disclosure of primary facts in audited accounts, notes, the tax audit report and computation supported the assessee&#039;s claim that the waiver amount was a capital receipt. The issue was treated as a debatable question of law, and the Court applied the settled principle that penalty under section 271(1)(c) cannot be imposed merely because a legal claim is rejected. Because the explanation was found bona fide and not shown to be false, an incorrect claim in law did not amount to concealment or furnishing inaccurate particulars, and the penalty was deleted.</description>
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