No Penalty U/s. 271(1)(c ) for human error with no willful concealment

Advocate Akhilesh Kumar Sah Jefferris India Pvt. Ltd. Vs. ACIT (ITAT Mumbai)  When there was no willful concealment and mistake involved human error, penalty under section 271(1)(c ) deleted Recently, in Jefferris India Pvt. Ltd. vs. ACIT [ITA No. 7397/Mum/2018 (A.Y. 2011-12), decided on 28-03-2019], brief facts of the case were that the assessee company filed its return of income for A.Y. 2011-12 declaring income of Rs. 9,78,51,166/-. The return of income was revised on 25.05.2012 declaring income of Rs. 9,58,51,166/-. In the revised return of income, the assessee revised reduction of disal...