No penalty u/s 271(1)(c) as mere claim isn’t furnishing inaccurate income particulars

ADIT Vs Fidelity Management & Research Co. (ITAT Mumbai)

Conclusion: Penalty under section 271(1)(c) was not leviable as  AO had not demonstrated any falsehood in the particulars provided by assessee. Mere making a claim that was not legally sustainable did not constitute furnishing inaccurate particulars of income

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