Section 271(1)(c)
Concealment penalty — Section 271(1)(c) (legacy)
Pre-AY 2017-18 penalty for concealment or furnishing inaccurate particulars. Still relevant for old years.
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As specified in the SCN — usually 15 to 30 days
Our fee tier
Scrutiny / Reassessment — ₹ 4,500 to ₹ 7,000
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Practising CA on the CA-Vetted plan
What this section is
Section 271(1)(c) — the precursor of Section 270A — levies penalty for concealment of particulars of income or furnishing inaccurate particulars. It applies to assessment years up to 2016-17. The seminal authority is CIT v. Reliance Petroproducts (SC, 2010).
When it is issued
Through a separate penalty SCN after assessment for AYs up to 2016-17.
What you should do
- 1Insist on the SCN clearly mentioning the limb invoked — concealment OR inaccurate particulars. A vague SCN is bad in law (per Karnataka HC in Manjunatha Cotton).
- 2Submit a detailed bona fide explanation. The bar of bona fide is reasonably low.
- 3Note that mere disallowance of a claim does not by itself attract penalty (Reliance Petroproducts).
Documents typically needed
- Assessment order and quantum appeal record
- Penalty SCN
- Working showing how the disputed claim was bona fide
Common mistakes
- Skipping the technical defence on the SCN form itself.
- Treating disallowed claims as automatic concealment.
Educational reference only
This guide is general in nature and does not constitute legal or tax advice on a specific notice. For advice tailored to your situation, please use the CA-Vetted plan or consult your own professional adviser.
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