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2015 (10) TMI 1476 - AT - Income TaxPenalty under section 271(1)(c) - reopening of assessment - Held that:- The assessee in this case has suo motu offered the additional income and the same was not detected during any course of action by the Revenue authorities against the assessee. Under such circumstances, it cannot be said to be a case where any concealment of income is detected against the assessee inviting penalty action under section 271(1)(c) of the Act. Hence, it cannot be said to be a case of concealment of income by the assessee so far as the assessment proceedings under section 147 are concerned. The assessment proceedings under section 147, as discussed above, were carried out just to validate the invalid revised return and not on account of any detection of escapement of income. In view of the above, we do not find it as a case fit for levy of penalty under section 271(1)(c). The penalty so levied by the lower authorities is, therefore, ordered to be deleted. - Decided in favour of assessee.
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