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TMI Blog2013 (8) TMI 969X X X X Extracts X X X X X X X X Extracts X X X X ..... sion that the income declared by the assessee from the long-term capital gain by selling agricultural land disclosed by the assessee in his revised return of income was accepted by the assessing authority and there was no material available on record by which there could be an inference drawn by the authority that it was a deliberate concealment on the part of the assessee and it could not be cons ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f penalty was initiated against the assessee by issuance of notice u/S. 271(1)(c) of the Act by the assessing authority considering it to be a case of deliberate concealment made by the assessee and after affording opportunity of hearing inflicted a penalty of ₹ 15,41,732 upon the assessee. 3. Against the order impugned, an appeal came to be filed before the CIT (Appeals) and the appellate ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... merely because the assessing authority had accepted the revised return of income, submitted by the assessee on 13th Aug., 2007 the proceeding initiated against the assessee u/S. 271(1)(c) of the Act and inflicting penalty upon the assessee for deliberate concealment, the observations of the CIT (Appeals) are confirmed by the Tribunal could not be held to be justified and the scope of s. 271(1)(c) ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sis for inflicting penalty upon the assessee in exercise of powers conferred u/S. 271(1)(c) of the Act. 7. We do not find any substance in the submissions made by counsel for appellant and apart from that even if there appears some substance, this Court has a limited scope in the instant appeal u/S. 260A of the Act, to examine it a substantial question of law arises for consideration. 8. Taking ..... X X X X Extracts X X X X X X X X Extracts X X X X
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