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,

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