2012 (11) TMI 677

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....been framed:- "Whether on the facts and in the circumstances of the case, the Tribunal is not justified in deleting the penalty imposed under Section 271(1)(c) on the ground that the assessee was in distressed and filed inaccurate particulars of income?" 2. A bare perusal of the order passed by the Tribunal will reveal that the Tribunal has not set aside the penalty under Section 271(1)(c) o....

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....ving this reason, the Tribunal has only taken note of the arguments of the assessee's representative that management of the assessee was in distressful state of mind during the relevant period. There is no finding of the Tribunal that because of this reason the order of penalty is wrong and mere recording of statement of the assessee's representative has been misunderstood to be a finding recorded....