100% Tax Evasion Penalty u/s 271(1)(c) Reviewed; Annual Family Gifts Not Proof of Income Concealment.

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....Levy of penalty @ 100% of the tax sought to be evaded u/s 271(1)(c) – one family giving gift to another family year after year, it can be said to be against human probabilities, but that may not be sufficient to hold the assessee guilty of concealment of income or furnishing of inaccurate particulars. - AT....