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    <title>2013 (12) TMI 553 - DELHI HIGH COURT</title>
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    <description>Penalty under section 271(1)(c) was examined in the context of a write-off of non-saleable and damaged stock. The Tribunal accepted the assessee&#039;s explanation that, as a food-processing and export business, it dealt with perishable goods subject to expiry, along with unusable packing material and items rendered unsaleable by changed specifications or brand requirements. It also relied on stock details and surrounding commercial circumstances to hold that the explanation was credible and that the burden under Explanation 1 had been discharged. On those factual findings, the deletion of penalty was upheld and no substantial question of law arose.</description>
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