No Penalty Under IT Act Section 271(1)(c) Without "Tax Sought to Be Evaded," Per Explanation 4. Assessee Non-Explanation Irrelevant.

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....Penalty u/s 271(1)(c) - there is no ‘tax sought to be evaded’, in terms of Explanation 4 to section 271(1)(c), on which penalty could be levied - even as the asessee has not furnished any explanation during the penalty proceedings or in the appellate proceedings no penalty is leviable....