No Penalty for Assessee on Deemed Dividend Misclassification u/ss 271(1)(c) and 2(22)(e) of Income Tax Act.

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....Penalty u/s 271(1)(c) - addition of deemed dividend u/s 2(22)(e) - the explanation of the transaction being commercial in nature for purchase of property - the explanation did not save it from the rigors of 2(22)(e), and therefore if the same was found false, it could not be said that the assessee had malafidely not returned the deemed income to tax - no penalty....