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    <title>2006 (5) TMI 84 - RAJASTHAN HIGH COURT</title>
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    <description>Penalty under section 17(1)(c) of the Gift-tax Act was not leviable where the assessee disclosed all primary facts in the return and before the assessing authority, and the dispute concerned only the legal character of the transactions. The court treated the issue as one of inference from fully disclosed facts, not concealment or furnishing of inaccurate particulars. As the relevant transfers, consideration and payments had been placed on record, the essential ingredients for concealment penalty were not established, and the penalty order was held unsustainable on the facts found.</description>
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      <description>Penalty under section 17(1)(c) of the Gift-tax Act was not leviable where the assessee disclosed all primary facts in the return and before the assessing authority, and the dispute concerned only the legal character of the transactions. The court treated the issue as one of inference from fully disclosed facts, not concealment or furnishing of inaccurate particulars. As the relevant transfers, consideration and payments had been placed on record, the essential ingredients for concealment penalty were not established, and the penalty order was held unsustainable on the facts found.</description>
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