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May 2024

Penalty u/section 271(1)(c) — Furnished inaccurate particulars of income — disallowance of claim of deduction u/s 36(i)(viii) of the Act.

By Ajay R. Singh, Advocate
Reading Time 3 mins

3 Pr. Commissioner of Income Tax-2 vs. ICICI Bank Ltd.

ITXA NO. 1067 OF 2018

Dated: 13th March, 2024, (Bom) (HC)

Penalty u/section 271(1)(c) — Furnished inaccurate particulars of income — disallowance of claim of deduction u/s 36(i)(viii) of the Act.

Assessee-respondent, a banking company, filed its return of income for A.Y. 1999–2000 on 31st December, 1999, declaring total income of ₹1,19,33,33,740 under the normal provisions. Assessee also declared book profit of ₹78,29,67,083 under section 115JA of the Act. Subsequently, assessee filed revised return of income on 27th February, 2001, declaring total income at ₹46,53,59,236 and book profit of ₹1,02,15,58,970. The Assessing Officer (AO) completed the assessment by disallowing certain deductions.

Assessee challenged the assessment order before the Commissioner of Income Tax (Appeals) (CIT(A)) and, thereafter, before the ITAT. When assessee’s appeal was pending before the ITAT, the AO iss

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