Penalty u/s 271(1)(c) Not Warranted for Capital Gain Valuation Discrepancies Without Evidence of Concealment.

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....Levy of penalty u/s 271(1)(c) - Computation of capital gain - assessee cannot be made subject levy of penalty under section 271(1)(c) of the Act merely for reason that the consideration shown in the computation of capital was less than the value adopted for stamp duty or the value determined by the DVO under the provision of section 50C.- AT....