Tax Penalty Dispute: Court Finds No Concealment, Only Classification Issue in Income Disclosure u/s 271(1)(c.

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....Penalty u/s 271(1)(c) - debatable issue - Since the assessee-respondent had not suppressed the amount in question and had disclosed it in its return, merely because he declared it under a particular “head of income”, and the AO chose to treat the same under some other head, the assessee-respondent cannot be accused of furnishing incorrect particulars of income or suppressing facts. - HC....