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2021 (6) TMI 654 - AT - Income TaxPenalty u/s 271(1)(c) - concealment of particulars of income or furnished inaccurate particulars - HELD THAT:- AO imposed penalty u/s 271(1)(c) of the Act on estimation basis without adducing any evidence on record for concealment of income. Penalty u/s 271(1)(c) of the Act is liable to be imposed only where the assessee has concealed its particulars of income or furnished inaccurate particulars. Action of making addition on ad–hoc basis does not result into imposition of penalty u/s 271(1)(c) of the Act and hence cannot be termed as either concealment or furnishing of inaccurate particulars of income. Penalty under section 271(1)(c) of the Act is liable to be imposed only where the assessee has concealed its particulars of income or furnished inaccurate particulars. Action of making addition on ad–hoc basis does not result into imposition of penalty u/s 271(1)(c) of the Act and hence cannot be termed as either concealment or furnishing of inaccurate particulars of income. - Decided against revenue.
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