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    <description>Penalty under section 271(1)(c) may be initiated on the basis of a fresh reassessment where the original assessment has been set aside and a new assessment directed. Earlier penalty proceedings dropped after the original assessment was annulled do not bar later action if concealment of income is ultimately found in the reassessment. The section was treated as wide enough to cover penalty proceedings arising from reassessment or remand-based assessments, so the later penalty initiation was held to be within jurisdiction.</description>
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      <description>Penalty under section 271(1)(c) may be initiated on the basis of a fresh reassessment where the original assessment has been set aside and a new assessment directed. Earlier penalty proceedings dropped after the original assessment was annulled do not bar later action if concealment of income is ultimately found in the reassessment. The section was treated as wide enough to cover penalty proceedings arising from reassessment or remand-based assessments, so the later penalty initiation was held to be within jurisdiction.</description>
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