Reliance Petroproducts - Penalty

Penalty under Section 271(1)(c) for furnishing inaccurate particulars.

Distinction between disallowance and concealment.

Mere disallowance of an inadmissible claim does not amount to concealment or inaccurate particulars. Penalty cannot be imposed merely because the assessee's claim is not accepted.

Penalty requires positive proof of concealment, not just adjustment of accepted facts.