2013 (2) TMI 49

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....s by the revenue arise out of the common order dated 22.06.2012 passed by the Income Tax Appellant Tribunal in ITA No.4076/Del/2011 and 4073/Del/2011 pertaining to the assessment years 2003-04 and 2004-05. 2. In both these matters the question is with regard to penalties under section 271(1)(c) of the Income Tax Act, 1961. In respect of the assessment year 2003-04 the penalty imposed by the ass....

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....sessee at the time of filing of the original return. The penalty has been levied on the respondent-assessee because the claim under section 80-IB in the revised return has not been accepted and has been reduced to Rs.2,52,41,632/-. Similar facts have arisen in respect of the assessment year 2004-05. 3. The Commissioner of Income Tax(Appeals) had deleted the said penalty and the revenue was in a....

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....t." We have already seen the meaning of the word "particulars" in the earlier part of this judgment. Reading the words in conjunction, they must mean the details supplied in the Return, which are not accurate, not exact or correct, not according to truth or erroneous. We must hasten to add here that in this case, there is no finding that any details supplied by the assessee in its Return were f....