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TMI Blog2023 (7) TMI 1388X X X X Extracts X X X X X X X X Extracts X X X X ..... granting of LTCG - HELD THAT:- Fact remains that the assessee at no point of time concealed its particulars of income or filed inaccurate particulars of income at any stage of revealing its income to the revenue authorities. Thus, in the present case Section 271(1)(c) does not apply as the assessee at no point of time concealed its income from the revenue authorities. Thus, the AO as well as the C ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e deleted. 2. The learned C.I.T.(Appeals) erred in confirming the penalty order u/s. 271(1)(c) of the learned Assessing Officer, particularly, when there was no concealment of particulars of income or no concealment of income and the same were duly reflected in the return of income and were fully substantiated during the course of assessment proceedings and only the income was converted from exemp ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... consideration received under Section 68 of the Act. The Assessing Officer initiated proceedings under Section 271(1)(c) for concealment of particulars of income thereby issuing notice on 22.12.2018. The assessee filed his reply. After taking cognizance of the reply the Assessing Officer levied penalty under Section 271(1)(c) for concealment of particulars of income for a sum of Rs. 42,876/- at the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... non-granting of LTCG. But the fact remains that the assessee at no point of time concealed its particulars of income or filed inaccurate particulars of income at any stage of revealing its income to the revenue authorities. Thus, in the present case Section 271(1)(c) does not apply as the assessee at no point of time concealed its income from the revenue authorities. Thus, the Assessing Officer a ..... X X X X Extracts X X X X X X X X Extracts X X X X
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