Penalty not automatic on deemed additions and omitted fixed deposit interest; each item must be independently tested for concealment.

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....Penalty under section 271(1)(c) was held not exigible on the addition relating to transfer of tenancy rights because the addition rested on the deeming fiction in section 50C, and the same reasoning used to delete penalty on the property transfer addition applied equally. Penalty was also deleted on the fixed deposit interest addition because the interest formed part of maturity proceeds, the investment was not disputed, and mere acceptance of the addition did not automatically establish concealment. The Tribunal held that each addition must be examined on its own facts before penalty can be imposed.....