Assessee's Penalty u/s 271(1)(c) Upheld for Failing to Substantiate Claims and Disprove Section 68 Addition.

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....Penalty u/s 271(1)(c) - addition u/s 68 - opportunities were provided by the AO to the assessee to substantiate its claim and to disprove the contention of the non-confirming party but the assessee failed to show any initiative as it had not shown any willingness for crossverification and cross-examination of the said party - penalty confirmed - AT....