Penalty u/s 271(1)(c) untenable as making of claim doesn’t amount to furnishing of inaccurate particulars

Trine Entertainment Limited Vs ITO (ITAT Mumbai) ITAT Mumbai held that penalty u/s 271(1)(c) not leviable as mere making of a claim which is not sustainable in law by itself will not amount to furnishing of inaccurate particulars of income. Facts- The assessee is engaged in business of developing online and offline games softwares in its 100% export oriented STPI unit. The assessment of the year under consideration was completed by the Assessing Officer under Section 143(3) of the Act on 31.12.2013, wherein, additions were made in respect of disallowances of claim of deduction u/s 10A, disallo...