2007 (7) TMI 223

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....M. M. KUMAR J.— The Revenue has approached this court by filing the instant appeal under section 260A of the Income-tax Act, 1961 (for brevity, "the Act"), and has challenged the order dated October 31, 2006, passed by the Income-tax Appellate Tribunal, Chandigarh Bench-A (for brevity, "the Tribunal"), in I. T. A. No. 649/Chandi/2005. The Tribunal has recorded a categorical finding that the gift....

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....hat no question of levy of penalty under section 271(1)(c) of the Act would arise. 2. It is an admitted position that the assessee had claimed that a sum of Rs. 1,00,000 was received from the NRE Account No. 67, maintained with the State Bank of Patiala, Kurali, by one Harcharan Singh. The aforementioned claim of the assessee was declined and further proceedings for imposition of penalty under ....

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....come have been duly declared, then it cannot be concluded that the assessee has concealed the particulars or has furnished inaccurate particulars of his income. It has also been held that mere observation of the Assessing Officer without recording any satisfaction concerning concealment of income was not sufficient for initiation of proceedings under section 271(1)(c) of the Act. On that additiona....