https://www.taxtmi.com/caselaws?id=786477 Where an assessing officer reclassified expenditures as capital and disallowed them, the question whether those outlays were revenue or capital in nature is a debatable question of law and fact; such a bona fide difference of opinion negates the element of concealment or furnishing of inaccurate particulars required to impose a punitive tax penalty. Because the disputed classification admitted reasonable argument and there was no finding of fraud or knowingly false particulars, the penal liability was held not leviable and the penalty was deleted. en-us Mon, 02 Feb 2026 00:00:00 +0530 Fri, 13 Feb 2026 09:18:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=786477 Where an assessing officer reclassified expenditures as capital and disallowed them, the question whether those outlays were revenue or capital in nature is a debatable question of law and fact; such a bona fide difference of opinion negates the element of concealment or furnishing of inaccurate particulars required to impose a punitive tax penalty. Because the disputed classification admitted reasonable argument and there was no finding of fraud or knowingly false particulars, the penal liability was held not leviable and the penalty was deleted. Case-Laws Income Tax Mon, 02 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=786477