A mere omission or negligence would not constitute a deliberate act of suppressio veri or suggestio falsi for imposition of penalty

Astra Housing & Investment P. Ltd Vs CIT (Delhi HC)- The crux of the ratio of above decisions is that a  mere omission or negligence would not constitute a deliberate act of suppressio veri or  suggestio falsi. In order to be covered within the proviso of clause (c) of sub-Section (1) of Section 271, there has to be concealment of particulars of income by the assessee or the assessee must have furnished inaccurate particulars of income. Incorrect claim may not amount to furnishing of inaccurate particulars. Everything depends upon the return filed by the assessee, because that is the onl...