Penalty u/s 271(1)(c) Challenged: No Income Concealment Found; Assessment and Penalty Proceedings Are Distinct.

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....Penalty u/s. 271(1)(c) - It cannot be said that assessee has concealed the particular income with the meaning of section 271(1)(c) of the Act or there is not deep concealment for attaining as specified u/s. 271(1)(c) - assessment proceedings and penalty proceedings are distinct and findings given in the assessment proceedings though it constitutes good evidence cannot be conclusive in the penalty proceedings. - AT....