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    <title>1997 (10) TMI 87 - ITAT AHMEDABAD-B</title>
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    <description>Penalty under s. 271(1)(c) was examined where reassessment added alleged unexplained investment based on a third-party noting in a telephone-cum-diary reflecting higher sale consideration than the registered agreement and conveyance. The Tribunal held that the noting, not authored by the assessee or spouse, contained internal contradictions (reference to the sale agreement price) and could plausibly reflect a bona fide slip of pen; the Revenue produced no corroborative material proving actual payment of the higher amount or a higher market value, and the acquisition authority&#039;s inaction supported the apparent consideration. As the addition was not final and no further evidence emerged in penalty proceedings, concealment or furnishing inaccurate particulars was not established; penalty was cancelled and the appeal allowed.</description>
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    <pubDate>Wed, 15 Oct 1997 00:00:00 +0530</pubDate>
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      <title>1997 (10) TMI 87 - ITAT AHMEDABAD-B</title>
      <link>https://www.taxtmi.com/caselaws?id=55997</link>
      <description>Penalty under s. 271(1)(c) was examined where reassessment added alleged unexplained investment based on a third-party noting in a telephone-cum-diary reflecting higher sale consideration than the registered agreement and conveyance. The Tribunal held that the noting, not authored by the assessee or spouse, contained internal contradictions (reference to the sale agreement price) and could plausibly reflect a bona fide slip of pen; the Revenue produced no corroborative material proving actual payment of the higher amount or a higher market value, and the acquisition authority&#039;s inaction supported the apparent consideration. As the addition was not final and no further evidence emerged in penalty proceedings, concealment or furnishing inaccurate particulars was not established; penalty was cancelled and the appeal allowed.</description>
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      <pubDate>Wed, 15 Oct 1997 00:00:00 +0530</pubDate>
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