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    <description>Penalty under section 271(1)(c) of the Income-tax Act was held unsustainable because the Tribunal found, on the evidence, that there was no concealment. That finding was treated as a factual conclusion based on appreciation of the record, and no perversity or legal error was shown to justify interference. On that basis, the penalty issue was decided against the Revenue and in favour of the assessee, and no substantial question of law was found to arise from the Tribunal&#039;s decision.</description>
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