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    <title>2017 (8) TMI 1685 - ITAT AHMEDABAD</title>
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    <description>A penalty for concealment was held unsustainable where the income addition arose from substitution of sale consideration under the section 50C deeming fiction, because such an adjustment for capital gains does not by itself conclusively establish concealment or inaccurate particulars. The commentary also notes that the small additional receipt was not supported by any separate and specific finding in the penalty order; it was merely clubbed with the larger addition. On that basis, the penalty under section 271(1)(c) was deleted.</description>
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      <description>A penalty for concealment was held unsustainable where the income addition arose from substitution of sale consideration under the section 50C deeming fiction, because such an adjustment for capital gains does not by itself conclusively establish concealment or inaccurate particulars. The commentary also notes that the small additional receipt was not supported by any separate and specific finding in the penalty order; it was merely clubbed with the larger addition. On that basis, the penalty under section 271(1)(c) was deleted.</description>
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