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    <description>The delay in filing the penalty appeal was condoned because the explanation was supported by affidavit and was not shown to be deliberate or mala fide, with a liberal reading of &quot;sufficient cause&quot; applied to advance substantial justice. Penalty under section 271(1)(c) was deleted because the additions were based on ad hoc disallowances, the assessee had been in custody and could not produce supporting records, and the surrender was treated as bona fide to buy peace with the Department. On those facts, concealment or furnishing of inaccurate particulars was not established merely because the assessment involved estimate-based additions.</description>
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      <description>The delay in filing the penalty appeal was condoned because the explanation was supported by affidavit and was not shown to be deliberate or mala fide, with a liberal reading of &quot;sufficient cause&quot; applied to advance substantial justice. Penalty under section 271(1)(c) was deleted because the additions were based on ad hoc disallowances, the assessee had been in custody and could not produce supporting records, and the surrender was treated as bona fide to buy peace with the Department. On those facts, concealment or furnishing of inaccurate particulars was not established merely because the assessment involved estimate-based additions.</description>
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