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2014 (1) TMI 140 - KERALA HIGH COURTPenalty u/s 271(1)(c) - Held that:- The vast difference between voluntary disclosed income and the income arrived by the Assessing Officer in the reassessment proceedings clearly indicates, there is concealment of income without even filing of the returns by the appellant-assessee in response to Section 148 notice. Mere reference to Explanation 3 to Section 271 would not imply that reassessment proceedings which led to penalty proceedings are based on deemed concealment of income. There was no occasion for the authorities to invoke this provision in the present situation. Quantum of penalty imposed by the Assessing Officer was substantially reduced by the CIT (Appeals) which came to be confirmed by the Tribunal - Decided against assessee.
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