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2011 (3) TMI 1014 - PUNJAB AND HARYANA HIGH COURTPenalty u/s 271(1)(c)- assessee had not complied with the provisions of Section 94(7) while furnishing its return of income - Held that:- In the opinion of the Tribunal, the judicial enunciations relied upon by the CIT(A) for deleting the penalty, were not applicable to the resolution of the controversy in hand and were clearly distinguishable on facts, and it was a clear case of non-compliance of Explanation-1 to Section 271(1)(c) of the Act. The Tribunal while embarking on the above issue observed that in the instant case the facts relating to disallowance of loss as per the provisions of sub-section (7) of Section 94 of the Act were not disclosed by the assessee in the return filed, and even if some explanation was offered by the assessee, the same was not bona fide because no reason had been given by the assessee for not making disallowance under Section 94(7) of the Act. No perversity or illegality could be pointed out by the learned counsel for the assessee in the findings recorded by the Tribunal that may persuade this Court to interfere therewith
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