Assessee sold a plot of land and received consideration in several instalments in different assessment years.  During relevant assessment year, assessee offered to tax amount of consideration which was received during previous year .  An assessment order was passed .  Later on, Assessing Officer issued a reopening notice against assessee raising objection with manner in which capital gains from sale agreement with respect to said plot was offered to tax by assessee on receipt basis . In response to same, assessee filed return withdrawing amount of capital gains and offering to tax capital gains on entire sale consideration .  Assessing Officer completed reassessment and taxed capital gains arising on entire sale consideration for relevant assessment year .  He also levied penalty under section 271(1)(c) on assessee for furnishing inaccurate particulars of income as a result of default committed by assessee in not offering capital gains arising out of entire sale consideration in relevant assessment year .  The levy of penalty was affirmed by the CIT (A) and Appellate Tribunal . On appeal the appellant  contended that there was a complete disclosure by assessee and, therefore, it was not a case of assessee furnishing inaccurate particulars of income or of concealing particulars of income .  It was noted that it was quite evident that assessee had declared full facts and sale agreement at first instance .  Full factual matrix or facts were before Assessing Officer while passing asessment order . The  assessee had never suppressed any material fact from revenue  it was another matter that claim based on such facts was found to be inadmissible .This was not same thing as furnishing inaccurate particulars of income as contemplated under section 271(1)(c)  . High Court deleted the penalty .  (AY. 2005-06)