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Penalty for inaccurate particulars fails where disclosed claims were disallowed in an unabated year without incriminating material.
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....Penalty under section 271(1)(c) could not be sustained where society charges and depreciation were disallowed only for want of supporting evidence or by following earlier years, because the claims were fully disclosed in the books and return and no false or inaccurate particulars were found. In an unabated year, additions under section 153C could not rest on routine disallowances without incriminating material. The Tribunal upheld deletion of the penalty, and the Revenue's challenge failed.....
TaxTMI