Penalty under section 271(1)(c) could not survive once the underlying quantum addition, which formed the sole basis of the penalty, had already been deleted in the assessee's own case and that fact was not disputed by the Revenue. The Tribunal treated the penalty as purely consequential to the assessment addition and held that, without a surviving addition, there was no basis to sustain the penalty. The order sustaining the penalty was set aside and the penalty deleted.
Penalty under section 271(1)(c) could not survive once the underlying quantum addition, which formed the sole basis of the penalty, had already been deleted in the assessee's own case and that fact was not disputed by the Revenue. The Tribunal treated the penalty as purely consequential to the assessment addition and held that, without a surviving addition, there was no basis to sustain the penalty. The order sustaining the penalty was set aside and the penalty deleted.
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