No Penalty for Income Escapement: Taxpayer's Revised Return Pre-Notice u/s 271(1)(c) Shows Non-Contumacious Conduct.

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....Penalty u/s 271(1)(c) - escapement of income come to notice in different year assessment proceedings - the assessee has duly submitted the revised return before the issue of notice u/s. 148 - assessment has been made on the basis of sums already declared - the assessee cannot be said to have acted contumacious manner so as to warrant levy of penalty....