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Assessee's evidence overlooked, penalty under Income Tax Act section 271(1)(c) dismissed; circumstances adequately explained.

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....Penalty levied u/s 271(1)(c) - the assessee has given evidences, on which no findings was given by Ld. CIT(A), in our view, the assessee reasonably explained the facts qua this addition before Ld. CIT(A. Therefore, in our view, this is not a fit case for sustaining the levy of penalty under section 271(1)(c) - AT....