Penalty u/s 271(1)(c) Deemed Inappropriate for Disclosed Loan as Deemed Dividend u/s 2(22)(e.

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....Penalty u/s 271(1)(c) - deemed dividend u/s 2(22)(e) - assessee in its balance sheet has disclosed loan from a sister concern, Therefore, it cannot be said that the assessee has furnished wrong particulars of income or had concealed any income - in a debatable issue and in a case like this where the assessee had furnished complete details of the transaction, the penalty cannot be imposed....