Misinterpretation of Penalty 271(1)(c): Rejected Tax Claims Don't Automatically Mean Penalties; Focus on Intentional Misrepresentation.

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....Penalty 271(1)(c) - if the contention of the Revenue is accepted, then in case of every Return where the claim made is not accepted by Assessing Officer for any reason, the assessee will invite penalty under Section 271(1)(c) and that is clearly not the intendment of the Legislature. - AT....