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2014 (10) TMI 867 - ITAT AHMEDABADPenalty u/s.271(1)(c) - Held that:- We find that the assessee has filed a detailed explanation regarding source of acquisition of jewellery found at the lime of survey. The assessee has also made a disclosure at the time of search proceedings, taking into consideration the on-money received on sale of land and certain other investment, and has disclosed an amount in its return of income filed in response to the notice under section 153A of the Act in the name of the assessee or his family members. We find that merely because the explanation of the assessee with regard to the acquisition of some part of the jewellery not accepted by the taxing authorities, it does not follow that the assessee was guilty of concealment of income or filing of inaccurate particulars of income. There is no material brought on record on behalf of the Revenue to suggest that the explanation of the assessee regarding source for acquisition of jewellery was not bond fide. In these facts of the case, we are of the view that it is not a fit case for imposition of penalty under section 271(l)(c) of the Act which is accordingly cancelled - Decided in favour of assessee.
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