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5.1 On the merits of the case, Ld. Counsel for the assessee stated that assessee filed its return Income of Rs. 35,29,470/- with income from investments i.e. dividends, capital gains and interest. He stated that AO taken the return of for scrutiny u/s. 143(2) of the Act under CASS and not income escaping based on the information on section 94(7) of the Act disallowance on information based on AIR. He further stated as per page no. 9-11 of the paper book, the AO has issued various notices u/s 143(2)/142(1) of the Act at pages 9 to 11 & order sheet at pages 12 to 16 of the Paper Book, the AO has not made any enquiry for the disallowance in the case of the assessee u/s. 94(7) of the Act. It was further submitted that AO on the basis of the query for dividend income on 07.12.2017 issued a notice u/s. 142(1) and asked the assessee to file the detail of all dividend / bonus income earned by the assessee in a specified format. In compliance of the same on 13.12.2017 Ld. Counsel for the assessee appeared and took adjournment for 15.12.2017 and examined all details of dividend / bonus income and found that there is an inadvertent clerical error committed by the Chartered Accountant and on the advice of Senior Chartered Accountant, the assessee filed voluntary revised computation of income wherein a Long Term Capital Gain (LTCG) of Rs. 14353921 has been increased to Rs. 34205795 due to the disallowance of Rs. 19851974 u/s. 94(7) of the Act at the first opportunity as soon as it came to the notice of the assesee. Assessee has committed this mistake of furnishing of inaccurate particulars in the return due to the inadvertent bonafide offer cited in the claim due to the one entry by the accounts staff posted at wrong date due to huge voluminous transactions and dividend coupons for dividend from same security punched at one voucher i.e. entry of two dividend received on same security (Rs. 1,98,51,874/- received on 28.1.2015 and Rs. 3,38,62,717/- received on 25.3.2015 made cumulatively on 26.3.2015 i.e. date of sale of investments (26.3.2015) and receipt date of second dividend. AO has completed the assessment on the basis of details furnished by the assessee. He further stated that under the circumstances assessee has not concealed or has not filed any inaccurate particulars of income. Assessee has paid voluntary paid taxes on disallowance u/s. 94(7) and not filed the appeal against the assessment order passed by the Assessing Officer. He further stated that assessee has not filed any false claim and has not concealed any particulars of income or furnished inaccurate particulars of income u/.s 271(1)© of the Act. He further stated that the term "Particulars" means 'Details'. Further it is held Terms "inaccurate particulars" and "inaccurate claim" are not same, as such it is not a case of furnishing inaccurate particulars since assessment finalized based on details furnished by assessee and no finding in penalty order by the AO or CIT(A) that any particulars furnished by assessee were wrong or particulars not furnished rather it is a case of inaccurate claim due to inadvertent human error. Therefore, he requested that penalty in dispute may be deleted in view of the judgment of the Hon'ble Supreme Court of India in the case of Reliance Petro Chemicals Ltd. 189 Taxman 322 (SC). In support of this contention assessee has filed two paper books and written synopsis and various case laws.