Penalty Proceedings u/s 271(1)(c): Evaluate Individual's Claim of Jewelry Taxed in 1997 VDIS Separately from Quantum Assessment.

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....Penalty u/s 271(1)(c) - accepted quantum addition - in penalty proceedings he offer explanation that the jewellery found during search were already offered to tax in the VDIS, 1997 - quantum assessment as well as the penalty proceedings are independent of each other - the explanation offered should be tested for its correctness and only if it is found to be palpably false or not acceptable, then the question of imposing the penalty would arise.....