Penalty u/s 271(1)(c) Not Justified if Assessee Complies with Will and Family Arrangement.

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....Penalty u/s 271(1)(c) - transfer of title - diversion of income by overriding title - Once assessee has complied with the terms of the Will and the family arrangement then, it cannot be held that at the time of filing of the return the assessee lacked genuine and bona fide belief or acted mala fidely to divert the income for evading the taxes. - AT....