https://www.taxtmi.com/caselaws?id=783622 Where the assessee claimed deduction for payments made to a bank to settle a sister concern's debt in its capacity as guarantor and to recover secured land, the ITAT held that penalty under s. 271(1)(c) could not be sustained because all primary facts supporting the claim were disclosed, negating any basis to record satisfaction of "concealment." The ITAT further held that the penalty notice/order was vitiated by an impermissible mismatch and ambiguity in charge: the AO initiated penalty for "concealment of income" but ultimately imposed penalty alleging "concealment or furnishing of inaccurate particulars," indicating uncertainty as to the applicable limb. Penalty was deleted and the appeal was allowed. en-us Wed, 03 Dec 2025 00:00:00 +0530 Fri, 19 Dec 2025 08:30:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783622 Where the assessee claimed deduction for payments made to a bank to settle a sister concern's debt in its capacity as guarantor and to recover secured land, the ITAT held that penalty under s. 271(1)(c) could not be sustained because all primary facts supporting the claim were disclosed, negating any basis to record satisfaction of "concealment." The ITAT further held that the penalty notice/order was vitiated by an impermissible mismatch and ambiguity in charge: the AO initiated penalty for "concealment of income" but ultimately imposed penalty alleging "concealment or furnishing of inaccurate particulars," indicating uncertainty as to the applicable limb. Penalty was deleted and the appeal was allowed. Case-Laws Income Tax Wed, 03 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783622