Penalty u/s 271(1)(c) Not Automatic for Unexplained Deposits; Legal Heir's Explanation Found Bona Fide.

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....Penalty u/s 271(1)(c) - failure on the part of legal heir of the deceased assessee to explain the source of part of the deposits - The mere failure on the part of the assessee/legal representative to explain the deposits in the bank accounts would not ipso facto lead to the conclusion that the assessee has either furnished inaccurate particulars of income or concealed the particulars of income. The explanation during the assessment proceedings by the legal representative of the deceased assessee is bona-fide as provided in Explanation 1(B) to section 271(1)(c) - AT....