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2014 (8) TMI 1093 - AT - Income TaxPenalty u/s.271(1)(c) - dividend striping u/s. 94(7) - assessee is a share broker and a share trader - concealment of income v/s bona fide mistake - Held that:- CIT(A) after going through the explanation submitted by the assessee has observed that it was not a case of concealment of income rather of bona fide mistake. The A.O. had not detected any concealment of income but had sought the details of disallowance u/s. 94(7) in ordinary course of assessment proceedings. The ld. CIT(A), therefore held that it was not a fit case for levy of penalty. AR submitted that the assessee has returned a total income of ₹ 12.25 crores. He, further, submitted that the disallowance prescribed u/s.94(7) is a statutory disallowance only. Accordingly, he submitted that there is no concealment of particulars of income on furnishing of inaccurate particulars of income. We find force in the submissions of the ld. AR. There is no infirmity in the order of the ld. CIT(A). - Decided against revenue
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