Penalty u/s 271(1)(c) Not Applicable for Income Added via Deeming Provision of Section 2(22)(e.

Levying penalty u/s 271(1 )(c) - addition u/s 2(22)(e) - the conscious act of furnishing of inaccurate particulars of income or concealment of income cannot be attributed to the assessee, specially when the addition u/s 2(22)(e) was made under the deeming provision - AT .....

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