https://www.taxtmi.com/caselaws?id=789503 Penalty under Section 271(1)(c) of the Income-tax Act, 1961 was held not leviable where the assessee had made a bona fide but legally unsustainable claim for double taxation relief on fully disclosed facts. The disallowance arose from interpretation of the treaty position and did not establish concealment of income or furnishing of inaccurate particulars. A mere rejection of a claim, even if incorrect in law, is insufficient to attract penalty unless the statutory ingredients of concealment or inaccuracy are proved. On that basis, the penalty was deleted in favour of the assessee. en-us Thu, 05 Feb 2026 00:00:00 +0530 Thu, 09 Apr 2026 08:09:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=789503 Penalty under Section 271(1)(c) of the Income-tax Act, 1961 was held not leviable where the assessee had made a bona fide but legally unsustainable claim for double taxation relief on fully disclosed facts. The disallowance arose from interpretation of the treaty position and did not establish concealment of income or furnishing of inaccurate particulars. A mere rejection of a claim, even if incorrect in law, is insufficient to attract penalty unless the statutory ingredients of concealment or inaccuracy are proved. On that basis, the penalty was deleted in favour of the assessee. Case-Laws Income Tax Thu, 05 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=789503