Penalty u/s. 271(1)(c) unsustainable in absence of concealment of income or furnishing inaccurate particulars

CIT Vs Shell Global Solutions International B.V. (Gujarat High Court) Gujarat High Court held that initiation of penalty proceedings u/s 271(1)(c) of the Income Tax Act in the absence of any material to establish the concealing of income or furnishing inaccurate particulars unsustainable-in-law. Facts- The respondent assessee company is a Foreign Company registered in Netherlands, deriving income from Royalties or fees for technical services. A return of income of Rs.9,19,53,530/- was filed. On verification of Form 3CEB, it was noticed that the assessee company had entered into international t...