Section 271(1)(c) Penalty Not Applicable for Section 69B Estimates from Government Valuer; No Automatic Guilt Assumption.

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....Penalty u/s 271(1)(c) - Though section 69B is a deeming fiction but in the matter of penalty proceedings, such deeming fiction cannot be extended so as to hold assessee guilty of concealment of income or furnishing of inaccurate particulars when the addition on account of deeming fiction is based on some kind of estimate given by a Govt. Valuer. - AT....