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    <title>1978 (7) TMI 139 - ITAT DELHI-C</title>
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    <description>Penalty cancellation for concealment was upheld on factual findings that the assessee&#039;s treatment of interest from partners and related adjustments was disclosed on an explained basis, followed earlier years, and was not contumacious. The Tribunal&#039;s conclusion that there was no mala fide concealment rested on appreciation of the record and inferences drawn from the facts. On that basis, no referable question of law arose under section 256(1), because a mere possibility of taking a different view of the facts did not convert the matter into a legal issue. The reference applications were dismissed.</description>
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    <pubDate>Wed, 19 Jul 1978 00:00:00 +0530</pubDate>
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      <title>1978 (7) TMI 139 - ITAT DELHI-C</title>
      <link>https://www.taxtmi.com/caselaws?id=64120</link>
      <description>Penalty cancellation for concealment was upheld on factual findings that the assessee&#039;s treatment of interest from partners and related adjustments was disclosed on an explained basis, followed earlier years, and was not contumacious. The Tribunal&#039;s conclusion that there was no mala fide concealment rested on appreciation of the record and inferences drawn from the facts. On that basis, no referable question of law arose under section 256(1), because a mere possibility of taking a different view of the facts did not convert the matter into a legal issue. The reference applications were dismissed.</description>
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      <pubDate>Wed, 19 Jul 1978 00:00:00 +0530</pubDate>
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