https://www.taxtmi.com/caselaws?id=365884 Penalty for concealment cannot be sustained where the assessee disclosed all material facts and advanced a bona fide legal interpretation that receipts were not taxable under the India-Singapore DTAA because the services did not make available technical knowledge under article 12(4)(b). The failure to contest the quantum addition did not, by itself, establish concealment or furnishing of inaccurate particulars. Bona fides must be assessed at the time the return is filed, and a debatable view supported by legal material does not amount to concealment absent a finding that the explanation was false or mala fide. On that basis, the statutory conditions for penalty were not met. en-us Wed, 06 Jun 2018 00:00:00 +0530 Sat, 25 Aug 2018 09:28:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=365884 Penalty for concealment cannot be sustained where the assessee disclosed all material facts and advanced a bona fide legal interpretation that receipts were not taxable under the India-Singapore DTAA because the services did not make available technical knowledge under article 12(4)(b). The failure to contest the quantum addition did not, by itself, establish concealment or furnishing of inaccurate particulars. Bona fides must be assessed at the time the return is filed, and a debatable view supported by legal material does not amount to concealment absent a finding that the explanation was false or mala fide. On that basis, the statutory conditions for penalty were not met. Case-Laws Income Tax Wed, 06 Jun 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=365884