Penalty u/s 271(1)(c) Not Applicable for Voluntary Separation Payments; Section 35DDA Argument Accepted.

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....Penalty u/s. 271(1)(c) - expenditure toward payment made to employees under Voluntary Separation Scheme - when the assets are in the process of being sold out, the employees are made to go and the business is being in the process of closure down. In these circumstances, the appellant’s contention that their case is not covered by the scheme contemplated by section 35DDA has to be accepted - AT....