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As per our considered opinion, the penalty can be imposed only where the conditions laid down u/s.271(1)(c) of the Act are satisfied, and the penalty is not an automatic consequence for every addition to returned income. Merely because an addition is made to the income declared by the assessee, penalty u/s.271(1)(c) could not be imposed.

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Section 80-IA, 271(1)(c) of IT Act, 1961—Penalty—Since the assessee had made disclosure by way of furnishing facts and material in computation of income and no information or statement given in return or during assessment proceedings was found to be factually incorrect or inaccurate, case of assessee could not be said to be a case of concealing particulars of income' or 'furnishing of inaccurate particulars of income' as contemplated under section 271(1)(c) of the Act. Shiv kumar sushil kumar Tea Vs. ACIT (No.2) (2019) 74 ITR(Trib) 432 (Jaipur)

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