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1971 (12) TMI 9 - ALLAHABAD HIGH COURTPenalty - concealment of income - fact that the assessee had been guilty of concealment in past years cannot lead to the inference that he is guilty of concealment in the year in dispute. The past record of the assessee was not relevant for the purpose of deciding as to whether there has been such concealment as to warrant imposition of penalty. As has been seen, penalty proceedings being quasi-criminal in nature, the facts necessary to attract the penal provision of section 271 of the Act must be clearly proved in respect of each year.
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