No Penalty for Misclassifying Stock Appreciation Rights as Capital Gains u/s 271(1)(c) of Income Tax Act.

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....Penalty u/s 271(1)(c) - assessee shown stock appreciation rights and gain as capital gain in place of perquisites under salary despite considering employer as perquisite - there had been a difference of opinion or difference in interpretation - it cannot be stated that the conduct of the assessee amounted to deliberate concealment of income with certain mala fide intentions or furnished inaccurate particulars of income - no penalty....