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    <title>1974 (9) TMI 12 - ALLAHABAD High Court</title>
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    <description>Penalty under section 28(1)(c) depended on whether the omission of income amounted to deliberate concealment and whether the Tribunal had considered relevant evidence. For one disputed item, the omission was treated as not deliberate and the no-penalty view was supported by the record. For the other item, the assessee&#039;s explanation was unproved, the omission persisted over several years, and the Tribunal relied on irrelevant material while ignoring relevant circumstances; that approach was held vitiated in law. The no-penalty finding was therefore sustained only for the first item and rejected for the second.</description>
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    <pubDate>Tue, 17 Sep 1974 00:00:00 +0530</pubDate>
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      <title>1974 (9) TMI 12 - ALLAHABAD High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=39031</link>
      <description>Penalty under section 28(1)(c) depended on whether the omission of income amounted to deliberate concealment and whether the Tribunal had considered relevant evidence. For one disputed item, the omission was treated as not deliberate and the no-penalty view was supported by the record. For the other item, the assessee&#039;s explanation was unproved, the omission persisted over several years, and the Tribunal relied on irrelevant material while ignoring relevant circumstances; that approach was held vitiated in law. The no-penalty finding was therefore sustained only for the first item and rejected for the second.</description>
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      <pubDate>Tue, 17 Sep 1974 00:00:00 +0530</pubDate>
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