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    <title>1981 (2) TMI 94 - ITAT ALLAHABAD-A</title>
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    <description>Penalty proceedings under section 271(1)(c) were validly initiated where satisfaction had been recorded in a separate order-sheet entry during assessment, even though the assessment order itself did not contain the direction to issue notice. On concealment, no penalty was justified because the assessee had disclosed all primary facts, including the relevant business details, and the addition arose only from a different inference drawn on the same disclosed material. In penalty proceedings, the assessee&#039;s explanation was tested on preponderance of probability and was found probable. The penalty order was therefore unsustainable.</description>
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    <pubDate>Fri, 20 Feb 1981 00:00:00 +0530</pubDate>
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      <title>1981 (2) TMI 94 - ITAT ALLAHABAD-A</title>
      <link>https://www.taxtmi.com/caselaws?id=56703</link>
      <description>Penalty proceedings under section 271(1)(c) were validly initiated where satisfaction had been recorded in a separate order-sheet entry during assessment, even though the assessment order itself did not contain the direction to issue notice. On concealment, no penalty was justified because the assessee had disclosed all primary facts, including the relevant business details, and the addition arose only from a different inference drawn on the same disclosed material. In penalty proceedings, the assessee&#039;s explanation was tested on preponderance of probability and was found probable. The penalty order was therefore unsustainable.</description>
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      <pubDate>Fri, 20 Feb 1981 00:00:00 +0530</pubDate>
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