Explanation 1 to section 271(1)(c) not applies to ‘furnishing inaccurate particulars of income’

Brief of the Case ITAT New Delhi held In the case of Tristar Intech Pvt. Ltd. vs. ACIT that for levy of penalty u/s 271(1)(c) there should be concealment of income on the part of assessee. In the given case AO has initiated penalty proceeding u/s 271(1)(c) on the basis that the assessee has concealed the particulars of income but penalty ultimately levied on the assessee for furnishing inaccurate particulars by the Explanation 1 to Section 271(1)(c). Explanation 1 is a deeming provision and is applicable only when an amount is added or disallowed in computation of total income which is deemed ...