Penalty U/s. 271(1)(c) cannot be imposed for mere non-application of Rule 8D by assessee

ITAT held in ACIT Vs Ms Shyam Basic that if the assessee had made a wrong claim in the return of income but had furnished full particulars in its return of income then it would not amount to concealment if income and penalty u/s 271(1)(c) could not be levied.

Moreover for levying of penalty u/s 271(1)(c) particulars had to be inaccurate and inaccurate particulars means the details filed in the return of income were not accurate or e

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