Penalty u/s 271(1)(c) Cannot Be Imposed Based on Section 50C Legal Fiction, Says CIT(A.

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....Penalty u/s 271 (1)(c) - capital gain assessed as per the provisions of section 50C/2(14) - The direction of CIT(A) is clear that penalty cannot be imposed on the basis of legal fiction of section 50C - He therefore, directed to work out the concealed capital gain in accordance with the sale value of the property - No infirmity into the direction of CIT(A). It would be open before the AO even to decide whether the land in question was a capital asset or not. - AT....