Levy of penalty under Section 271(1)(c) of the Income Tax Act: Between Legal Intent and Factual Circumstances

Furnishing inaccurate particulars: claiming non existent depreciation can attract penalty even without willful concealment; notice must be specific.

Claiming depreciation on non existent assets constitutes furnishing inaccurate particulars of income under the penalty provision; proof of willful concealment is not a necessary ingredient for civil penalty liability. Notices initiating penalty proceedings must be specific and clear to meet natural justice requirements, and factual admissions and reversal of disputed claims are operative in determining whether inaccurate particulars were furnished.