Penalty u/s 271(1)(c) Explanation 5A Invalidated Due to Revenue's Failure to Meet Prerequisites.

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....Penalty u/s 271(1)(c) - The prerequisites towards applicability of Explanation-5A has not been demonstrated by the Revenue either in the penalty order or the first appellate order thereon. Thus, the imposition of penalty under the shelter of Explanation 5A is clearly without sanction of law. - AT....