TMI Blog2019 (4) TMI 1133X X X X Extracts X X X X X X X X Extracts X X X X ..... e penalty, the CIT(A) and the Tribunal both concurrently held that mere difference in estimation of the value of the land as on 1.4.1981 would not give rise to penalty. The Tribunal recorded that there was neither any concealment of income or particulars thereof. The CIT(A) also highlighted the point of diversion between two sides why there was wide gap between two valuations; one presented by the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Tribunal was correct in deleting the penalty u/S. 271(1)(c) even though it was agreed that quantum of income determined is certainly not beyond the shadow of doubts? 4. Brief facts are as under:- Respondent assessee during the period relevant to the assessment year in question namely 2004-05 had sold immovable property in the nature of land and declared capital gain arising out of such sa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nalty, the CIT(A) and the Tribunal both concurrently held that mere difference in estimation of the value of the land as on 1.4.1981 would not give rise to penalty. The Tribunal recorded that there was neither any concealment of income or particulars thereof. The CIT(A) also highlighted the point of diversion between two sides why there was wide gap between two valuations; one presented by the ass ..... X X X X Extracts X X X X X X X X Extracts X X X X
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