No Penalty for Concealment u/s 271(1)(c) if High Court Admits Substantial Question on Quantum Proceedings.

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....Penalty u/s. 271(1)(c) - unexplained cash credit u/s. 68 - Once, the substantial question of law on the quantum proceedings is admitted by the Hon'ble High Court, the issue in dispute became debatable. Hence, there cannot be any concealment penalty of the assessee for alleged furnishing of inaccurate particulars of income. - AT....