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    <title>2000 (10) TMI 29 - DELHI High Court</title>
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    <description>Penalty under section 271(1)(c) could not be levied without proof of concealment, and an agreement to be assessed at a particular figure did not by itself establish concealment. Because the assessment and reassessment related to an earlier period under the 1922 Act and were completed before 1 April 1964, the Explanation inserted from that date did not apply. The Revenue was therefore required to prove concealment independently before penalty could be imposed, and the issue was decided in favour of the assessee.</description>
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      <description>Penalty under section 271(1)(c) could not be levied without proof of concealment, and an agreement to be assessed at a particular figure did not by itself establish concealment. Because the assessment and reassessment related to an earlier period under the 1922 Act and were completed before 1 April 1964, the Explanation inserted from that date did not apply. The Revenue was therefore required to prove concealment independently before penalty could be imposed, and the issue was decided in favour of the assessee.</description>
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