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2011 (7) TMI 109 - HC - Income TaxPenalty - Addition - Estimated by registered valuer - It is further evident in the instant case that apart from the disclosing such rental income in its computation of income the assessee had also produced copy of the rent/lease agreement (entered between the assessee and the Bank of Punjab Limited, which was duly signed by both the parties and was duly registered) before the AO which further substantiates the assessee‟s contention that there was no intention of the assessee to conceal any particulars of income - principle of law laid down by the various judgments cited by both the sides about which there is no quarrel. The question is whether the conditions stipulated in Section 23(1) are satisfied in the instant case - it is evident that the assessee had planned its affairs in such a way that minimum tax would be payable - explanation of the assessee was not bona fide. Explanation 1 to Section 271(1)(c) of the Act would be fully applicable and the AO was justified in imposing the penalty which was upheld upto the Tribunal level. - Decided against the assessee
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