Penalty u/s 271(1)(c) - Addition u/s 68 - Head changed from income under “PGBP” (as shown by the...

Penalty u/s 271(1)(c) - Addition u/s 68 - Head changed from income under “PGBP” (as shown by the assessee) to addition U/s 68 - That there was some tax sought to be evaded by assessee, is a necessary condition for imposition of penalty U/s 271(1)(c) - The allegation of the Ld. CIT(A) that the assessee had the bogus income or bogus credit, is pointless, because the corresponding amount was already included in the returned income of the assessee. - AT .....

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