Penalty for inaccurate particulars fails when the sole bad-debt disallowance is deleted, leaving no related tax liability.

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....Penalty for furnishing inaccurate particulars cannot survive where it rests solely on a bad-debt disallowance that has been deleted. Once the Tribunal deleted the quantum addition and the High Court confirmed that deletion, no tax liability remained in respect of the disallowance. The consequential penalty for concealment or furnishing inaccurate particulars was therefore deleted, with the Tribunal's deletion sustained and the revenue's appeal dismissed.....