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Penalty under section 271(1)(c) deleted where income was disclosed in section 153A returns and remaining additions were only estimated or computational.
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Penalty under section 271(1)(c) was held unsustainable where the income had already been disclosed in returns filed in response to section 153A notices and accepted in assessment, because such disclosure could not by itself amount to concealment or furnishing inaccurate particulars. The Tribunal also found that the remaining additions were only estimated deemed brokerage adjustments and calculation errors, which did not meet the statutory threshold for penalty. On those facts, the penalties for the relevant assessment years were deleted.
Penalty under section 271(1)(c) was held unsustainable where the income had already been disclosed in returns filed in response to section 153A notices and accepted in assessment, because such disclosure could not by itself amount to concealment or furnishing inaccurate particulars. The Tribunal also found that the remaining additions were only estimated deemed brokerage adjustments and calculation errors, which did not meet the statutory threshold for penalty. On those facts, the penalties for the relevant assessment years were deleted.
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