Tribunal Member's Dissent: Penalty Not Automatic Without Concealment; Favorable Interpretation Possible for Assessee.

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....DST - The imposition of penalty is not automatic even assuming that the reassessment was justified. The fact that there was a dissenting opinion by one of the Members of the Tribunal, does indicate that it is not a case of concealment of particulars but a case where there is a possible interpretation in favour of the Assessee. - HC....