Penalty U/s. 271(1)(c) cannot be imposed for mere non-application of Rule 8D by assessee

Brief of the case: ITAT held in ACIT Vs Ms Shyam Basic that if the assessee had made a wrong claim in the return of income but had furnished full particulars in its return of income then it would not amount to concealment if income and penalty u/s 271(1)(c) could not be levied. Moreover for levying of penalty u/s 271(1)(c) particulars had to be inaccurate and inaccurate particulars means the details filed in the return of income were not accurate or exact or correct according to truth or erroneous. Facts of the case: Assessee had received dividend of Rs 1,83,157/- which was an exempt income. T...