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Court Overturns Penalty Decisions Due to Uncertainty in Misrepresentation and Expense Claims Under Income Tax Act.

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....Revision u/s 264 - penalty u/s 270A imposed - waiver of penalty u/s 270AA - The very fact that the indications were made that the matter fall within (a) and (c), necessarily means that even the revisional authority was not sure whether it was a case of misrepresentation or suppression of facts or claim of expense, not substantiated by any evidence. - Order passed by the assessing authority rejecting application u/s 270AA and the order passed by the revisional authority rejecting revision petition, cannot be sustained. - HC....