Penalty Not Justified u/s 271(1)(c) If Taxpayer Fully Disclosed Facts and Did Not Appeal Assessment Addition.

Penalty u/s 271(1)(c) - Disclosure of relevant facts - 1/5th ROC expenditure allowable u/s 35D - if all necessary details were made available by the assessee, the mere fact that the addition made in the course of assessment proceedings in the peculiar facts was not challenged in appeal by itself is neither here nor there is not sufficient to levy of penalty. .....

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