Penalty u/s 271(1)(c) Challenged: Loss Disallowance Based on Speculation, Lacks Concrete Evidence.

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....Penalty under section 271(1)(c) - disallowance of loss - Except non production of books, no reason or basis whatsoever has been assigned by authorities below in disallowing the entire loss. Thus disallowance is based on pure guesswork and not on any cogent reason. - AT....