TMI Blog1997 (8) TMI 103X X X X Extracts X X X X X X X X Extracts X X X X ..... ee. 3. The learned Departmental Representative relied upon the reasons mentioned in the penalty order as well as in the order of the CIT(A). 4. We have considered the submissions made by the learned representatives of the parties and have perused the orders of the learned Departmental authorities. 5. The AO has levied penalty under s. 271(1)(c) in respect of the following additions: ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... y. 6. On a careful consideration of the entire relevant facts, we are of the view that the disputed additions referred to above cannot be treated as concealment of income by the assessee. The assessee has discharged the burden of proving that the amount of cash credits added in their hand does not represent real income of the assessee by producing the affidavits of both the creditors. The disall ..... X X X X Extracts X X X X X X X X Extracts X X X X
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