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2022 (11) TMI 1135 - AT - Income TaxPenalty u/s 271(1)(c) - concealment of income or furnishing of inaccurate particulars of income - Disallowance of deduction u/s 80P - AO disallowed the interest by taking a view that as per provisions of Section 80P(2), the interest income earned from cooperative society is not eligible for deduction - HELD THAT:- We find that the AO while passing the assessment order, made disallowance of deduction under section 80P(2) and also added interest income earned from nationalised banks. Interest income earned from nationalised banks was not disclosed by the assessee in its return of income. Assessee could not substantiate the fact that the interest income was offered for taxation in the computation of income. Thus, it was a clear case of concealment of particulars of income, thus, the penalty qua such interest income of Rs. 524,223/- is upheld. So far as the other addition/disallowance Assessee has disclosed such interest income in return of income and addition was made due to change of opinion. Thus, there was no concealment on the part of Assessing Officer in claiming such deduction. Thus, the penalty qua such addition is deleted. This appeal of assessee is partly allowed.
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