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2019 (1) TMI 543 - HC - Income TaxPenalty levied u/s 271(1)(c) - assessee filed the revised return of income only after the survey action u/s 133A taken place in the premises of the purchaser - treat the revised return as return filed in response to the notice under Section 148 - Held that:- Tribunal was of the view that it was not a case where penalty could be levied under Section 271(1)(c) of the Act because the entire addition resulted from the voluntary disclosure by the assessee, though omitted to be disclosed while filing the original return of income due to bona fide reasons. In our considered view, the CIT(A) as well as the Tribunal considered the factual position and were satisfied that the contentions advanced by the assessee were bona fide. Thus, we find that no substantial question of law arises for consideration in these appeals. - decided against revenue
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