Income Tax Penalty u/s 158BFA(2): Assessment and Penalty Proceedings Are Distinct; Concrete Proof Needed for Penalty.

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....Penalty under section 158BFA(2) - Assessment proceedings and penalty proceedings are different and independent to each other. The addition or part of the addition could be sustained on the preponderance of probabilities, but in penalty proceeding, some proof is required, to impose penalty on the assessee - AT....