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2013 (12) TMI 1152 - GUJARAT HIGH COURTPenalty u/s. 271(1)(c) – Disallowances in scrutiny assessment - Held that:- Following CIT v. Reliance Petroproducts Pvt. Ltd. [2010 (3) TMI 80 - SUPREME COURT] - The assessee respondent, in its return of income, had disclosed all details and material particulars - It is a different aspect that Assessing Officer made certain additions in the scrutiny assessment. However later on, CIT (Appeals) had treated it differently by allowing and deleting certain additions - This cannot give rise to the penalty proceedings - For levying penalty u/s.271(1)(c), non bona fide conduct of the assessee should be apparent from the facts and circumstances – Decided against Revenue.
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