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    <title>1996 (4) TMI 73 - PATNA High Court</title>
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    <description>Penalty under section 271(1)(c) was examined in the context of disallowed expenses treated as capital in nature and unrelated to the relevant year. The Tribunal found, on the material before it, that there was no concealment of income and that any presumption against the assessee stood rebutted. The matter was treated as a genuine difference of opinion rather than concealment. On that basis, the penalty was held unsustainable and the issue was decided in favour of the assessee.</description>
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      <description>Penalty under section 271(1)(c) was examined in the context of disallowed expenses treated as capital in nature and unrelated to the relevant year. The Tribunal found, on the material before it, that there was no concealment of income and that any presumption against the assessee stood rebutted. The matter was treated as a genuine difference of opinion rather than concealment. On that basis, the penalty was held unsustainable and the issue was decided in favour of the assessee.</description>
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