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    <title>1977 (3) TMI 63 - ITAT HYDERABAD-B</title>
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    <description>The Tribunal found that the penalty under Section 271(1)(c) of the Income Tax Act, 1961, could not be sustained as the basis for the penalty, the unexplained investment, was deleted. The Tribunal held that the Inspecting Assistant Commissioner (IAC) acted without jurisdiction in levying the penalty based on estimated income from money-lending transactions, which was not the original ground for the penalty. Additionally, the Explanation to Section 271(1)(c) did not apply as the assessee did not commit fraud or willful neglect. Therefore, the Tribunal canceled the penalty, and the appeal was allowed.</description>
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    <pubDate>Thu, 17 Mar 1977 00:00:00 +0530</pubDate>
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      <title>1977 (3) TMI 63 - ITAT HYDERABAD-B</title>
      <link>https://www.taxtmi.com/caselaws?id=66724</link>
      <description>The Tribunal found that the penalty under Section 271(1)(c) of the Income Tax Act, 1961, could not be sustained as the basis for the penalty, the unexplained investment, was deleted. The Tribunal held that the Inspecting Assistant Commissioner (IAC) acted without jurisdiction in levying the penalty based on estimated income from money-lending transactions, which was not the original ground for the penalty. Additionally, the Explanation to Section 271(1)(c) did not apply as the assessee did not commit fraud or willful neglect. Therefore, the Tribunal canceled the penalty, and the appeal was allowed.</description>
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      <pubDate>Thu, 17 Mar 1977 00:00:00 +0530</pubDate>
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