Summary
- The Amritsar ITAT has deleted a ₹71,10,000 penalty under Section 271(1)(c) against Ferozepur Central Co Operative Bank for claiming genuine interest expenditure in the wrong assessment year.
- The Tribunal determined that the issue was a timing error, not a case of inaccurate particulars, as the interest belonged to Assessment Year 2011-12 but was claimed in Assessment Year 2012-13.
- The Tribunal noted the assessee's voluntary correction after discovering the mistake and emphasized that no penalty should apply for genuine errors.
- This ruling highlights that a sustained disallowance does not automatically imply inaccurate particulars, setting a precedent for similar cases involving timing discrepancies in expense claims.
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