Villo Noshir Anklesaria (Mrs.) v. ACIT (2021) 89 ITR 31 (SN) (Pune)(Trib.)

S. 271(1)(c) : Penalty-Concealment-Disclosing full facts-Levy of penalty is held to be not justified. [S. 54F]

 

Held that the assessee had declared the full facts; the full factual matrix or facts were before the Assessing Officer while passing the assessment order. It was another matter that the claim based on such facts were found to be inadmissible. This was not the same thing as furnishing inaccurate particulars of income as contemplated under   section 271(1)(c) of the Act. Levy of penalty is held to be not justified. (AY. 2007-08)