No Penalty Imposed: Section 271(1)(c) Exemption Denied but No Malafide Intent in Self-Generated Goodwill Case.

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....Penalty u/s 271(1)(c) - addition sustained by denying the exemption u/s 47(xiv) to the extent of self-generated Goodwill - all the details necessary for assessment were very much available in the return of income itself as well as the entire facts of proprietory concern getting converted into public limited company - no malafide on the part of the assessee in making the claim of exemption - no penalty....