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2017 (12) TMI 633 - GUJARAT HIGH COURTAddition u/s 274 r.w.s 271(1)(c) - claim for deduction of bad and doubtful debts at the rate of 10% of the average advances made by the assessee’s rural branches - Held that:- Merely making of a claim which was not accepted or not acceptable to the Revenue would not tantamount to furnishing of inaccurate particulars so as to attract the provisions of section 271(1)(c) of the Act. In the facts of the present case, the entire penalty order is based upon the facts as placed by the assessee on the record. Thus, merely because the assessee had made a claim which came to be disallowed, the provisions of section 271(1) (c) of the Act would not be attracted. Under the circumstances, the Tribunal was wholly justified in holding that there was nothing to indicate that the assessee had furnished inaccurate particulars of income warranting imposition of penalty under section 271(1)(c) of the Act. See Commissioner of Income-tax v. Reliance Petroproducts (P) Ltd. [2010 (3) TMI 80 - SUPREME COURT ] - Decided in favour of assessee.
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