Penalties u/s 271(1)(c) of Income Tax Act: Imposed Only for Deliberate, Defiant, or Conscious Non-Compliance.

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....Penalty u/s 271(1)(c) - quasi criminal proceedings - penalty will not ordinarily be imposed unless the party obliged under the Act has either acted deliberately in defiance of law or was guilty of conduct contumacious or acted in conscious disregard of its obligation. - AT....