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TMI Blog2019 (6) TMI 434X X X X Extracts X X X X X X X X Extracts X X X X ..... the Revenue and in the said document the interest portion has been shown as not applicable . If the department itself has not given a proper quantification, it will not be appropriate on part of the Revenue to take a plea that the assessee filed inaccurate particulars of income. In fact the assessee has offered the refund amount to the tax authorities. Therefore, the Assessing Officer as well as ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n-after referred to as the 'CIT (Appeals)) is bad in law and wrong on facts and must be quashed. 2. That on the facts and in the circumstances of the case, the learned CIT (Appeals) has erred in confirming the penalty u/s 271(1)(c) of the Income Tax Act, 1961 in respect of interest on income tax refunds not received by the appellant. 3. That on the facts of th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... and disallowance of expenses u/s 14A. Penalty proceedings u/s 271(1)(c) of the Act for furnishing inaccurate particulars of income were also initiated by the Assessing Officer and penalty notice was issued on 09.01.2015. The Assessing Officer u/s 271(1)(c) has imposed penalty of ₹ 3,53,210/- in respect of furnishing of inaccurate particulars of income to the extent of ₹ 9,56,835/- whi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t order. 7. We have heard both the parties and perused all the material available on record. The CIT(A) invoked Sec. 271(1)(c) of the Act and that too the limb of of inaccurate particulars of income filed by assessee. The Revenue has to clearly state as to which particulars are not being filed accurately. Form 26AS is the document issued by the Revenue and in the said docu ..... X X X X Extracts X X X X X X X X Extracts X X X X
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