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2010 (10) TMI 719 - AT - Wealth-taxPenalty u/s 18(1)(c) - Tax evasion - Ignorance of law - it will be seen that there is no concealment vis-āvis wealth assessed and wealth returned and only the concealment is confined to non-filing of the return of wealth for the first time as mentioned in explanation 3 of section 18(1) of the Wealth Tax Act - in the light of the provisions contained in Explanation 3 to sec. 18(1)(c), the assessee shall for the purpose of sec. 18(1)(c) of the Act, be deemed to have concealed the particulars of his assets or furnished inaccurate particulars of any assets or debts in respect of the assessment yeas under consideration - It was further submitted by the assessee that it is only with effect from 1.04.1993 that the word company' was added in sec. 3(1) for bringing charge of levy of the wealth-tax on the companies under the Wealth-tax Act, 1957 itself - it is thus clear that the assessee has not been above to prove and establish that the assessee has acted bonafidely, and it was under bona fide belief that it was not required to pay tax in the Assessment Years 1991-92 and 1992-93 - Appeal is allowed
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