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    <description>Whether penalty under section 271(1)(c) applies where a receipt from a foreign trust was disclosed and its taxability was debatable: tribunal applied the principle that full disclosure of material facts combined with a bona fide legal view supported by professional advice and divergent judicial opinions negates concealment or furnishing of inaccurate particulars; because the assessee had disclosed the receipt, furnished particulars, advanced a reasonable legal position and the department produced no evidence of mala fides or falsehood, the penalty was held unsustainable and deleted, appeal allowed in favour of the assessee.</description>
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