Penalty under section 18(1)(c) of the Wealth-tax Act--Cases where tolerance margin of 25% is exceeded because of disallowance of disputed tax liability.

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....cause of disallowance of disputed tax liability. The Board have received representations that even in cases where the disputed income-tax and wealth-tax demands, outstanding on the valuation date, are disallowed and such disallowances account for the shortfall of the returned wealth by more than 25% of the assessed wealth, some Wealth-tax Officers have been levying penalty under section 18(1)(c) ....