https://www.taxtmi.com/caselaws?id=181046 Where all primary facts are fully disclosed and the addition arises only from a bona fide difference in interpretation or classification of income, penalty for concealment or furnishing inaccurate particulars cannot be imposed under section 271(1)(c). The assessee had produced the relevant agreements, accounts, correspondence and computations, and the dispute turned on the correct head of income rather than on any hidden receipt, fabricated document, suppression, or new incriminating material. On those facts, rejection of the assessee's legal characterisation did not establish concealment, so the penalty was rightly deleted. en-us Fri, 29 Oct 1999 00:00:00 +0530 Wed, 06 Apr 2016 12:57:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=181046 Where all primary facts are fully disclosed and the addition arises only from a bona fide difference in interpretation or classification of income, penalty for concealment or furnishing inaccurate particulars cannot be imposed under section 271(1)(c). The assessee had produced the relevant agreements, accounts, correspondence and computations, and the dispute turned on the correct head of income rather than on any hidden receipt, fabricated document, suppression, or new incriminating material. On those facts, rejection of the assessee's legal characterisation did not establish concealment, so the penalty was rightly deleted. Case-Laws Income Tax Fri, 29 Oct 1999 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=181046