The assessee-bank made a bona fide claim for a deduction under section 36(1)(viii), which is linked to its business profit. The Assessing Officer recomputed the business profit, leading to a consequential disallowance of the claimed deduction, and thereafter imposed a penalty under section 271(1)(c). Upholding the order of the Tribunal, the High Court held that where a variance in an allowable deduction is merely a consequence of the recomputation of business profit by the Assessing Officer, it cannot be said that the assessee has furnished inaccurate particulars of income. The mere making of a bona fide claim that is ultimately not sustained in law does not, by itself, attract a penalty for furnishing inaccurate particulars. (AY. 1999-00)