Section 271(1)(c) Penalty Cannot Be Imposed for Valuation Differences Without Proof of Inaccuracy: SC

Dilip N. Shroff Vs JCIT (Supreme Court of India) In Supreme Court of India, the case concerns imposition of penalty under Section 271(1)(c) of the Income Tax Act, 1961 on an assessee HUF for allegedly furnishing inaccurate particulars of income. The assessee had declared long-term capital loss arising from sale of a 1/4th undivided share in a Mumbai property, supported by a valuation report from a registered valuer estimating the fair market value as on 01.04.1981 at ₹2.52 crore. The Assessing Officer referred the matter to a District Valuation Officer (DVO), who determined a significantly l...