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of Penalty u/s 271(1)(c) - Addition on account of non-genuine gifts - Penalty proceedings are separate and independent. It is an admitted fact that assessee offered the additional income, though, after issuing notice under section 142(1) by AO. Assessee was having in position of certain evidence in the form of declaration, details of donor and PAN number which were furnished the AO. It is also an admitted fact that no efforts were made by AO by issuing any notice to the donor under section 133(6) of the Act or any summon under section 133(1) of the Act. Facts remaining same that a gift received by assessee was treated as non-genuine gift for the want of complete evidence - No penalty - AT
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