Penalty u/s 271(1)(c) Requires Proof of Income Concealment, Not Just Commission Disallowance.

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....Penalty u/s 271(1)(c) - disallowance of liasoning commission - satisfaction regarding concealment of income - Merely because the commission expenses have been disallowed in the assessment year under appeal and confirmed by the appellate authority, by itself is no ground to levy the penalty.....