Decoding the Penalty Provisions under Section 271(1)(c): Analyzing the Fine Line Between Concealment and Inaccuracy in Taxation

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..... he Bombay High Court delves into the intricate aspects of the Income Tax Act, particularly focusing on the imposition of penalties under Section 271(1)(c). The case presents a significant exploration of the nuances in distinguishing between 'concealment of income' and 'furnishing inaccurate particulars of income,' two pivotal concepts in tax law jurisprudence. Background The crux .....

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..... ealment of particulars of income' and 'furnishing inaccurate particulars of income,' which are distinct grounds for penalty under the Act. * Defective Notice and Legal Implications: The appellant contended that the notice issued under Section 274, read with Section 271, was defective, impacting the validity of the penalty proceedings. Court's Analysis and Conclusion * Conc .....

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..... s not sustainable as the core charge of furnishing inaccurate particulars of income was not established. Implications and Significance This judgment is a landmark in clarifying the scope and application of penalties under Section 271(1)(c) of the Income Tax Act. It underscores the need for precision in tax notices and reaffirms the principle that penalties cannot be imposed merely on the basis o .....

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