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2015 (10) TMI 2639 - AT - Income TaxPenalty u/s 271(1)(c ) - income found in the locker - Held that:- Concealment and furnishing inaccurate particulars are different. The AO, while issuing notice, has to come to the conclusion as to whether it is a case of concealment of income or whether it is a case of furnishing of inaccurate particulars. The Hon’ble Apex Court in the case of T. Ashok Pai vs. CIT (2007 (5) TMI 199 - SUPREME Court) has held that concealment of income and furnishing inaccurate particulars of income carry different connotations. As in the present case the penalty order does not make it clear as to whether the penalty has been imposed for concealing particulars of income or for furnishing inaccurate particulars of income we respectfully following the decision in the case of Commissioner of Income Tax & Another vs. Manjunatha Cotton & Ginning Factory (2013 (7) TMI 620 - KARNATAKA HIGH COURT) wherein held that Notice u/s 274 of the Act should specifically state the grounds mentioned in section 271(1)(c) , i.e. whether it is for concealment of income or for furnishing of inaccurate particulars of income. Sending printed form where all the ground mentioned in section 271 are mentioned would not satisfy requirement of law, thus we hold that the penalty imposed u/s 271(1)(c) of the Act was improperly imposed by the AO - Decided in favour of assessee
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