Income Tax Act Section 271(1)(c): No 'mens rea' needed for penalties; unsustainable claims don't equal inaccurate income particulars.

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....Penalty u/s 271(1)(c) - Whether 'mens rea' or deliberate attempt is not essential for levy of penalty - A mere making of the claim, which is not sustainable in law, by itself, will not amount to furnishing inaccurate particulars regarding the income of the assessee. Such a claim made in the return cannot amount to furnishing the inaccurate particulars. - HC....