Penalty u/s 271(1)(c) Cannot Rely on Deeming Provisions of Section 50C for Justification.

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....Penalty u/s. 271(1)(c) - The addition has been made by invoking deeming provisions of section 50C. In our considered view in assessment proceedings the provisions u/s. 50C can be invoked for making addition, however penalty cannot be levied on the basis of such deeming provisions. - AT....