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Tribunal Reinstates Penalty for Concealment Despite Voluntary Disclosure; ITAT to Reconsider Unraised Penalty Issues u/s 271(1)(c).
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....Penalty u/s 271(1)(c) - While apparently surrendering all the income on its own by the Assessee ought not to have attracted penalty for concealment under Section 271(1)(c) Tribunal has not only restored the penalty by the impugned order but also restored the penalty on the issue for which no ground was raised in the Grounds of Appeal filed by the Revenue before it. - Matter restored before ITAT - HC....