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    <title>2004 (9) TMI 294 - ITAT AHMEDABAD-B</title>
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    <description>The Tribunal found that the penalty imposed by the Assessing Officer under s. 271(1)(c) was not justified as the offer made by the assessee for taxation was voluntary and conditional. The Tribunal held that the AO failed to establish concealment independently and solely relied on the conditional offer. It was emphasized that conditional admissions cannot be a basis for penalty without evidence of concealment. Consequently, the penalty was deleted, and the assessee&#039;s appeals were allowed.</description>
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    <pubDate>Fri, 24 Sep 2004 00:00:00 +0530</pubDate>
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      <title>2004 (9) TMI 294 - ITAT AHMEDABAD-B</title>
      <link>https://www.taxtmi.com/caselaws?id=56016</link>
      <description>The Tribunal found that the penalty imposed by the Assessing Officer under s. 271(1)(c) was not justified as the offer made by the assessee for taxation was voluntary and conditional. The Tribunal held that the AO failed to establish concealment independently and solely relied on the conditional offer. It was emphasized that conditional admissions cannot be a basis for penalty without evidence of concealment. Consequently, the penalty was deleted, and the assessee&#039;s appeals were allowed.</description>
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      <pubDate>Fri, 24 Sep 2004 00:00:00 +0530</pubDate>
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