No Penalty for Taxpayer: Tribunal Rules Belief of Non-Taxable Income Valid u/s 271(1)(c) Explanation 3.

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....Levy of penalty u/s 271(1)(c) - Capital gain on sale of property - Allegation of the AO that, return of income has not been filed voluntarily - There was a reasonable cause with the assessee for not filing the return originally within prescribed time as he holds a belief that his taxable income was below the taxable limit and no tax liability arises - Therefore, given the reasonable cause for non-filing the return of income, one of the essential conditions for invocation of explanation 3 to section 271(1)(c) is not satisfied - No penalty - AT....