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Income Tax Act Section 221(1): Discretionary Penalties for Non-Compliance; Assessing Officers Consider Circumstances Before Imposing Penalties.

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....Levy of penalty u/s. 221(1) - Reading of Sec. 221 shows that the Explanation wherein as “may” not “shall” which is subjective of the fact that imposition of penalty is neither automatic nor mandatory. The discretion is left with the A.O to decide whether to impose penalty or not, by considering the explanation of the assessee. - AT....