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2006 (1) TMI 66 - HC - Income TaxPenalty under section 271(1)(c) - Income-tax Appellate Tribunal, after noticing the Ordinance issued by the Central Government, coupled with the fact of the Reserve Bank of India refusing to exchange the high denomination notes when they were tendered for exchange, has come to the conclusion, that on the day, when the assessee was found to be in possession of high denomination notes, they were only scraps of paper and they could not be used as circulating medium in general use as the representative value and, therefore, it could not be said that the assessee was in possession of unexplained money, appears to us the correct, proper and reasonable conclusion. Therefore, the high denomination notes which were in the possession of the assessee as on January 24, 1978, cannot be said as "unexplained money", which the assessee had not disclosed in his return of income and, therefore, it would not warrant levy of penalty under section 271(1)(c) of the Act.
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