Penalty u/s 271(a)(c) Requires Evidence of Income Concealment or Inaccuracy; Not Automatic, Says High Court.

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....Penalty could have not been imposed as per Section 271(a)(c) of the Act without satisfying concealment or submission of inaccurate particulars of income on the part of the assessee. Such satisfaction must reflect in the order of assessment as the penalty as per the provision under consideration is not automatic - HC....