Penalty Under Sec 271(1)(c) Can't Be Imposed Without Evaluating Explanation on Liability Cessation Under Sec 41(1).

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....Penalty u/s 271(1)(c) - cessation of liability u/s 41(1) in respect of two trade creditors and in respect of one trade debtor - penalty in this case can not be imposed by merely referring to the alleged surrender and without considering the explanation. - AT....