That the assessee submitted that its services were not made available to the Indian entities. Such explanation of the assessee was rejected. It was not the case of the Department that the assessee had made any false claim. It could not be said that the submission or claim of the assessee was not accurate. Therefore the penalty was liable to be deleted. ( AY.2014-15)
Inspectorate International Ltd. v. ACIT (2018) 65 ITR 333/ 171 ITD 630 (Delhi) (Trib)
S. 271(1)(c) : Penalty – Concealment – Furnishing of inaccurate particulars of income — Mere rejection of claim — Penalty not leviable . [ 9(1)(vii) ]