Penalty u/s 271(1)(c) Challenged: Flawed Decision on Trust or Beneficiary Taxation Considered u/s 61(1).

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....Levy of penalty under section 271(1)(c). - taxability of income in the hands of trust or beneficiary - applicability of provisions of Section 61(1) - The orders of AO levying penalty is not only bad in law but also on facts - AT....