Straight-line lease rental accounting change and disclosed AS-19 interpretation for allegedly furnishing inaccurate particulars-penalty u/s 271(1)(c) quashed

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....Change to straight-line lease rental accounting was disclosed in audited financial statements and involved two plausible interpretations of the relevant accounting standard; the taxpayer adopted a bona fide, arguable view and made full disclosure, and therefore penalty under section 271(1)(c) for allegedly furnishing inaccurate particulars could not be sustained because imposition of penalty requires concealment or proven falsity and assessment additions alone do not establish inaccuracy. The result was quashing of the penalty directed at the taxpayer in respect of the straight-line lease rental claim.....