Penalty u/s 271(1)(c) Not Justified: Disclosure Discrepancy in Land Transaction Doesn't Warrant Penalty Imposition.

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....Penalty u/s 271(1)(c) - assessee disclosed all the true facts relating to the land - it may be a good case for making addition since there was difference between the actual consideration and the stamp duty value - but not a good case where penalty u/s 271(1)(c) may be levied as It is well settled that the penalty proceedings are different and distinct from the assessment proceedings....