Penalty u/s 271(1)(c) of Income Tax Act Dismissed; Explanation 5A "Transaction" Argument Rejected.

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....Penalty u/s 271(1)(c) - surrender of income - suo motu further income declared in the returns filed u/s 153A - Explanation 5A has specific application, the contention of ld. DR. that penalty are sustainable due to the implication of word transaction mentioned in sub clause ii of explanation. 5A cannot be accepted. - AT....