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2018 (8) TMI 1367 - AT - Income TaxLevy of penalty u/s 271(1)(c) - assessee contended that, mere acceptance of the disallowance by the Appellant does not tantamount to furnishing of inaccurate particulars of income and more particularly on account of the fact that the Appellant had suo-moto accepted the disallowance and decided not to file any appeal with the ITAT to avoid genuine hardship, mitigate compliance cost and facilitate liquidation process and in view of the substantial past losses which would eventually lapse going forward. - assessee also contended that, the disallowances made represent just 1% of the expenses which is highly immaterial with the nature of business and expenses incurred by the company. Held that:- In present year as well it is not a case of the Revenue that assessee furnished inaccurate particulars of the income or there is concealment of income on part of the assessee. Thus, the provisions of Section 271(1)(c) of the Act will not be attracted in the present case as well. - Penalty deleted - Decided in favor of assessee.
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