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EXPLANATION 2 TO SECTION 271(1)(C)

Income Tax - Penalties - Circumstances, Procedures and Relief - 03 - Additions are sometimes made by the assessing Officer for purely technical reasons, e.g., application of a presumptive rate of gross profit or of yield, or on account of estimated disallowance of certain expenses, shortfalls, wastage, etc., but no penalty for concealment is levied in respect of these additions for want of adequate evidence to establish that these additions represent the assessee s concealed income. In later ass .....

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espect of the year in which the deposit was made as there was no concealment in that year, the deposit having been explained as out of an earlier year s income. Explanation 2 to section 271 provides that in such cases, the assessee would become liable to penalty for concealment in respect of additions made in the earlier year in which the additions were made. Explanation 2 is applicable where the following conditions are satisfied: The source of any receipt, deposit, outgoing or investment in an .....

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