2006 (7) TMI 696

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....n the facts and in the circumstances of the case, and in law, the Income Tax Appellate Tribunal is right in coming to the conclusion that in the case of loss, penalty under Section 271(1)(c) of the Incometax Act cannot be imposed in view of the judgment of the Honourable Supreme Court in the case of CIT vs. Prithpalsingh, reported in 249 ITR 670, without considering the provisions of Explanation 4....