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    <title>1987 (5) TMI 47 - ITAT AMRITSAR</title>
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    <description>Penalty under section 271(1)(c) was considered in two contexts: amount disclosed under the Voluntary Disclosure of Income and Wealth Act but omitted from the return, and cash credits shown in partners&#039; accounts as alleged chit fund receipts. On the first, the explanation that the amount was omitted because it was believed to be covered by the disclosure scheme was treated as bona fide, especially where disclosure preceded the return and the Department already had the information; the penalty deeming fiction was therefore not attracted. On the second, the partners&#039; identity and capacity were not disputed and the explanation was not shown to be false, so the addition did not justify concealment penalty.</description>
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    <pubDate>Fri, 01 May 1987 00:00:00 +0530</pubDate>
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      <title>1987 (5) TMI 47 - ITAT AMRITSAR</title>
      <link>https://www.taxtmi.com/caselaws?id=57198</link>
      <description>Penalty under section 271(1)(c) was considered in two contexts: amount disclosed under the Voluntary Disclosure of Income and Wealth Act but omitted from the return, and cash credits shown in partners&#039; accounts as alleged chit fund receipts. On the first, the explanation that the amount was omitted because it was believed to be covered by the disclosure scheme was treated as bona fide, especially where disclosure preceded the return and the Department already had the information; the penalty deeming fiction was therefore not attracted. On the second, the partners&#039; identity and capacity were not disputed and the explanation was not shown to be false, so the addition did not justify concealment penalty.</description>
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      <pubDate>Fri, 01 May 1987 00:00:00 +0530</pubDate>
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