https://www.taxtmi.com/caselaws?id=277743 The Tribunal upheld the CIT(A)'s decision to cancel the penalty of Rs. 17,35,000 under section 271(1)(c). The Tribunal emphasized the requirement for the Department to provide sufficient evidence in penalty cases, particularly when invoking deeming provisions like section 69A. It highlighted the significance of proper interpretation and application of legal fictions, ultimately affirming the deletion of the penalty due to the lack of conclusive evidence supporting the additions made by the AO. The Departmental appeal was dismissed, reiterating the necessity for meeting the burden of proof in penalty proceedings. en-us Sun, 20 Sep 2015 00:00:00 +0530 Fri, 21 Dec 2018 05:51:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=277743 The Tribunal upheld the CIT(A)'s decision to cancel the penalty of Rs. 17,35,000 under section 271(1)(c). The Tribunal emphasized the requirement for the Department to provide sufficient evidence in penalty cases, particularly when invoking deeming provisions like section 69A. It highlighted the significance of proper interpretation and application of legal fictions, ultimately affirming the deletion of the penalty due to the lack of conclusive evidence supporting the additions made by the AO. The Departmental appeal was dismissed, reiterating the necessity for meeting the burden of proof in penalty proceedings. Case-Laws Income Tax Sun, 20 Sep 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=277743