Penalty notice u/s 271(1)(c) upheld for unexplained trading cost difference. Assessee's explanation inconsistent. Penalty imposed.

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....The Appellate Tribunal considered the validity of a penalty notice u/s 271(1)(c) and u/s 274 regarding unexplained differences in trading sales and purchase costs. The Tribunal found the notice u/s 274 not vague and upheld the penalty due to the inability of the assessee to substantiate accounts. The Tribunal highlighted the importance of strong reasons for selling goods below cost and the need for accurate valuation. The penalty was imposed based on inconsistencies in the assessee's claims and lack of transparency in accounts. The Tribunal emphasized the burden of proof on the assessee and the necessity to address all observations made by the assessing officer. The Tribunal allowed the appeal partially for statistical purposes.....