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Income Tax - Highlights / Catch Notes

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Penalty u/s. 271(1)(c) - As the penalty proceedings are distinct ...


Penalty u/s 271(1)(c) Requires Independent Verification; Additions in Quantum Proceedings Insufficient for Imposing Penalties.

April 15, 2022

Case Laws     Income Tax     AT

Penalty u/s. 271(1)(c) - As the penalty proceedings are distinct and independent to the quantum proceedings, in our considered view, penalty cannot be levied merely on the reasoning that some addition was made by the AO during the quantum proceedings. There has to be independent verification by the revenue authorities with respect to the additions made during the quantum proceedings to arrive at the satisfaction that the assessee has concealed the particulars of income. But we find that, the authorities below have not done so. - AT

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