Depreciation option claims with full disclosure and bona fide revision do not establish inaccurate income particulars for penalty.

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....A power-generating undertaking may exercise the second proviso to rule 5(1A) option to claim depreciation under rule 5(1) and Appendix I through its return and disclosed computation, as no separate form or prescribed mode is required. A depreciation claim does not constitute furnishing inaccurate particulars where asset details, cost, use, rates and computation are fully disclosed and no primary fact, entry or asset is false or bogus. Voluntary revision before a specific depreciation query may support bona fides, even if made during assessment after the revised-return period. Explanation 1 to section 271(1)(c) does not apply where the taxpayer's explanation is substantiated, bona fide and accompanied by full disclosure of material facts.....