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2001 (9) TMI 15 - HC - Income TaxThe appellant has sought to challenge the order passed by the Income-tax Appellate Tribunal sustaining the levy of penalty under section 271(1)(c) in respect of additions made in the income of the appellant as a result of cash found in his possession, the source of which was not explained to the satisfaction of the assessing authority. - In view of the finding reached by the Revenue in penalty proceedings independently about not furnishing of explanation by the assessee in penalty proceedings and explanation on record to be false, the Explanation springs to life in the penalty proceedings. Therefore, levying of penalty, in our opinion, has rightly been upheld by the Tribunal. The answer being self-evident and primarily being dependent on appreciation of evidence, no substantial question of law arises in the facts and circumstances of this appeal for consideration of this court.
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