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Income Tax - Highlights / Catch Notes

Home Highlights September 2020 Year 2020 This

Penalty u/s 271(1)(c) - The authorities have failed to ...

Case Laws     Income Tax

September 3, 2020

Penalty u/s 271(1)(c) - The authorities have failed to appreciate that the penalty proceeding and the assessment proceeding are distinct and since, the assessee had not commenced the business, therefore, it could not have earned income, which had not been accounted for. Tribunal has failed to take into account the well settled legal principles that mere disbelief of an explanation will not be sufficient to impose penalty. - HC

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