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    <description>Penalty under section 271(1)(c) of the Income-tax Act, 1961 is leviable even where the assessed income is a loss and the returned loss is reduced in assessment. The governing principle treated the levy as not dependent on positive taxable income, and the relevant amendment to section 271(1)(c) was regarded as retrospective. On that basis, cancellation of penalty solely because both the returned and assessed figures were losses was unsustainable.</description>
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