Penalty U/s. 271(1)(c) for mere change of head of income is not justified

ACIT Vs Krishna C. Tandon (HUF) (ITAT Mumbai) In this case penalty proceedings were initiated during quantum assessment for furnishing of inaccurate particulars. The assessee contested the same on the premises that full particulars were furnished in the return of income and there was no concealment of income and mere change of head of income do not justify imposition of penalty. However, not convinced, Ld. AO invoking Explanation-1 to Section 271(1)(c), levied penalty of Rs.60,59,108/- vide order dated 28/03/2014. ITAT that penalty has been imposed for merely change of head of income whereas t...