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2013 (10) TMI 1421 - AT - Income TaxPenalty u/s 271(1)(c) - Held that:- We find that the case squarely falls within the parameters of "ignorance", even by the CA, who conducted audit and tax audit. In such a case, the bonafide of the assessee gets explained automatically. In these circumstances, the penalty, in our opinion cannot be levied on the assessee. In so far as the bonafides of the CA firm is concerned, even the Hon'ble Supreme Court has accepted the fact that certain "silly mistakes" can never be ruled out. We, therefore, cannot hold even the CA to be guilty of committing a mistake, because, the relevant expression was inserted in the relevant assessment year only which went unnoticed by everyone.
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