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1977 (7) TMI 91 - AT - Income TaxExtract: .......ld that this was the concealed income of the assessee of this year. Where addition is made by merely rejecting the explanation of the assessee, it cannot be held that the assessee is guilty of concealment. In such circumstances the imposition of penalty cannot be held to be justified. We, therefore, cancel the order of penalty and allow the appeal.
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