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2019 (1) TMI 292 - ITAT PANAJIPenalty levied u/s. 271(1)(c) - non specification of charge - various disallowance made - proof of concealment of income or of furnishing inaccurate particulars of income - Held that:- From explanation by the assessee, we find that the additions have been made by not accepting the claim of the assessee. There is no case of concealment of income or furnishing of inaccurate particulars of income. The mere fact that assessee has not filed appeal against the additions, cannot be taken for adverse inference that the levy of penalty is automatic. This view is duly supported by the decision of Hon’ble Apex Court in the case of Reliance Petroproducts (P.) Ltd.[2010 (3) TMI 80 - SUPREME COURT] - decided in favour of assessee.
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