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2009 (10) TMI 583 - ITAT AGRAPenalty u/ s. 271(1)(c)- As per Hon'ble Supreme Court in the case of Dilip N. Shroff vs. Jt. CIT & Anr. [2007 -TMI - 6564 - SUPREME Court] held that the phrases "concealment of income" and "furnishing inaccurate particulars" are different. Both referred to deliberate act on the part of the assessee. Thus one cannot be substituted for the other - Even after the retrospective amendment, there is no provision that two limbs will be counted as one for the purpose of levy of penalty - Accordingly, even after retrospective amendment, there is no mistake apparent on record - The miscellaneous application is dismissed.
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