Penalty Order Valid Despite Initial Uncertainty if Definitive Charge Established in Section 271(1)(c) Cases.

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....Penalty u/s 271(1)(c) - unaccounted purchases - Even if the AO was not certain about the charge at the time of initiation of the penalty proceedings but he has given a definite conclusive finding regarding the default or charge at the time of passing the penalty order then no default cannot be found in the penalty order. - AT....