Revised return with same info is furnishing of inaccurate particulars

Brief of the case:

The ITAT Chennai in the case of DCIT vs. M/s. Rattha Citadines held that relying on the same information as available on the date of filing original return of income in filling revised return but making a different claim , in the absence of assessee’s bonafide expenditure would be deemed as furnishing of inaccurate particulars of income making assessee liable to face penalty u/s 271(1)(c).

Facts of the case:

• The assessee filed the return of income on 14-10-2010 declaring Nil income which was revised subsequently on 18-03-2011 declaring a loss of Rs. 1,23,51,488/- after adjusting the notional income of C4,76,517/- computed on account of restatement of foreign currency loan liability. During the course of assessment the said loss claim made in the revised return was disallowed by the AO and assessed the income of Rs. 4,76,517/-.

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