https://www.taxtmi.com/caselaws?id=186342 Penalty under Section 271(1)(c) was held unsustainable where the disallowance arose from a debatable Section 14A controversy and there was no concealment of income. The authorities treated the underlying tax position as highly arguable, so the assessee's claim could not be treated as furnishing inaccurate particulars merely because the deduction under Section 36(1)(iii) was disallowed on a Section 14A basis. The Tribunal's remarks on the assessee's intention in holding shares were clarified as submissions, not an operative finding affecting the result. The deletion of penalty was therefore upheld in favour of the assessee. en-us Thu, 05 Aug 2010 00:00:00 +0530 Wed, 14 Sep 2016 18:18:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=186342 Penalty under Section 271(1)(c) was held unsustainable where the disallowance arose from a debatable Section 14A controversy and there was no concealment of income. The authorities treated the underlying tax position as highly arguable, so the assessee's claim could not be treated as furnishing inaccurate particulars merely because the deduction under Section 36(1)(iii) was disallowed on a Section 14A basis. The Tribunal's remarks on the assessee's intention in holding shares were clarified as submissions, not an operative finding affecting the result. The deletion of penalty was therefore upheld in favour of the assessee. Case-Laws Income Tax Thu, 05 Aug 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=186342