https://www.taxtmi.com/caselaws?id=756982 Penalty under section 271(1)(c) was deleted because the assessee had disclosed all primary facts, including the cancellation of its banking licence, and the disallowance arose only from a technical claim for set-off of brought-forward losses. An unsustainable claim, without an independent finding of concealment or furnishing of inaccurate particulars, does not by itself justify penalty. The notice under section 274 also failed to clearly specify whether the charge was concealment or inaccurate particulars, which further weakened the penalty proceedings. en-us Fri, 09 Aug 2024 00:00:00 +0530 Tue, 13 Aug 2024 07:07:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=756982 Penalty under section 271(1)(c) was deleted because the assessee had disclosed all primary facts, including the cancellation of its banking licence, and the disallowance arose only from a technical claim for set-off of brought-forward losses. An unsustainable claim, without an independent finding of concealment or furnishing of inaccurate particulars, does not by itself justify penalty. The notice under section 274 also failed to clearly specify whether the charge was concealment or inaccurate particulars, which further weakened the penalty proceedings. Case-Laws Income Tax Fri, 09 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=756982