https://www.taxtmi.com/caselaws?id=757419 Penalty under section 271(1)(c) was held unsustainable where the addition arose from disallowance of interest expenditure claimed against interest income under section 57(iii). The decisive principle was that a mere disallowance in quantum proceedings does not, by itself, satisfy the conditions for penalty; rejection of the claim did not automatically establish concealment of income or furnishing of inaccurate particulars. On the record, the penal provision could not be applied only because the expenditure claim was found unsubstantiated in assessment, and the penalty was deleted. en-us Thu, 22 Aug 2024 00:00:00 +0530 Fri, 23 Aug 2024 18:25:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=757419 Penalty under section 271(1)(c) was held unsustainable where the addition arose from disallowance of interest expenditure claimed against interest income under section 57(iii). The decisive principle was that a mere disallowance in quantum proceedings does not, by itself, satisfy the conditions for penalty; rejection of the claim did not automatically establish concealment of income or furnishing of inaccurate particulars. On the record, the penal provision could not be applied only because the expenditure claim was found unsubstantiated in assessment, and the penalty was deleted. Case-Laws Income Tax Thu, 22 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=757419