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Whether the Appellate Tribunal has correctly appreciated the facts on record while confirming the order of the CIT(A) cancelling the penalty levied u/S.271(1)(c) of the Act?

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Section 271(1)(c) of the Income-tax Act, 1961—Penalty—Concealment Penalty - Penalty proceedings is quasi criminal proceedings and the burden is on the Revenue to establish that the disputed amount represented the income of the assessee and the assessee has consciously concealed the particulars of income and in the case of assessee, nothing of any such has been proved by the Revenue, rather, the assessee has disclosed all the details and there is no concealment of any particulars of income,thus, no penalty u/s. 271(1)(c) is leviable in this respet - CIT V/s HIRALAL AMRITLAL PAREKH & CO. - [2018] 2 ITCD Online 114 (DEL)

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