Contested Penalty u/s 271(1)(c) Overruled Due to Lack of Evidence and Invalid Confession in Tax Case.

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....Penalty u/s 271(1)(c) - return filed disclosing higher income u/s 153A - no incriminating material found - when the Revenue could not lay hands on any tangible material except conditional and tacit averments, which confession in itself is seen to be non-admission of any ingenuity - no hesitation to hold that such confession u/s 139(4) cannot be the basis for imposition of onerous penalty....