https://www.taxtmi.com/caselaws?id=468007 Penalty under section 271(1)(c) is not attracted where the assessee has disclosed all primary facts and the dispute concerns a debatable issue on taxability under section 41(1). The Tribunal held that penalty proceedings are distinct from assessment proceedings, so sustaining the addition in quantum does not by itself establish concealment or furnishing of inaccurate particulars. As the assessee's explanation was found bona fide and there was no material showing conscious inaccuracy, the requirements of Explanation 1 to section 271(1)(c) were not met. Penalty was therefore deleted. en-us Fri, 30 May 2014 00:00:00 +0530 Mon, 13 Apr 2026 10:56:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468007 Penalty under section 271(1)(c) is not attracted where the assessee has disclosed all primary facts and the dispute concerns a debatable issue on taxability under section 41(1). The Tribunal held that penalty proceedings are distinct from assessment proceedings, so sustaining the addition in quantum does not by itself establish concealment or furnishing of inaccurate particulars. As the assessee's explanation was found bona fide and there was no material showing conscious inaccuracy, the requirements of Explanation 1 to section 271(1)(c) were not met. Penalty was therefore deleted. Case-Laws Income Tax Fri, 30 May 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468007