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Section 271(1)(c) of the Act imposes strict liability on the assessee for concealment of income. There is no doubt that in the instantcase, there was concealment by the assessee. The mere fact that he had consented to the additions made would not exonerate the assessee from the liability to pay penalty. The penalty has been reduced to 200% by the Tribunal.

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Sec. 263 of Income Tax Act, 1961 – Revision – Section 271(1)(c) of the Act imposes strict liability on the assessee for concealment of income. There is no doubt that in the instant case, there was concealment by the assessee. The mere fact that he had consented to the additions made would not exonerate the assessee from the liability to pay penalty. The CIT exercising his revisional jurisdiction under Section 263 of the Act proceeded against the assessee and held that it is a fit case for imposing a maximum penalty of 300% which was reduced to 200% by the Tribunal. High Court dismissed the appeal of the assessee – MALANADU TOURIST HOME [2020] 423 ITR 262 (KER)

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