Penalty u/s 271(1)(c) Incorrectly Imposed Due to Misassumption of No Business Activity from Lack of Income.

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....Penalty u/s 271(1)(c) - The AO as well as the CIT(A) only proceeded on the basis that there was no income during the year therefore there is no business activity, but the same is fallacy and cannot be taken as the basis for imposing the penalty. - AT....