Levy of penalty u/s.271(1)(c) - default u/s. 2(22)(e) - the assessee has no explanation for his conduct...

Levy of penalty u/s.271(1)(c) - default u/s. 2(22)(e) - the assessee has no explanation for his conduct in not returning the impugned income - This, despite being aware of the provision being attracted - also there is shift in the assessee’s stand with time - levy of penalty confirmed - AT .....

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