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1992 (8) TMI 119 - AT - Income TaxExtract: .......e. There is no mens rea in the conduct of the assessee. If the explanation remains substantiated, no penalty is leviable under section 271(1)(c) though such explanation was liable to be rejected by the assessing authority. Thus, in any view of the matter, penalty under section 271(1)(c) cannot be sustained. 9. In the result, the appeals are allowed
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