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The special leave petition is dismissed.

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Sec. 271(1)(c) of the Income-tax Act, 1961 – Penalty – Revenue filed Tax Appeal against the order of Tribunal in deleting the penalty under section 271 [1](c) of the IT Act, 1961 with respect to claim of the assessee for deduction under section 36 [1] (viii) of the Act. The Tribunal deleted the penalty primarily on the ground that the explanation rendered by the assessee was reasonable. High Court dismissed the Tax Appeal of the revenue holding that ”on the similar circumstances, in case of this very assessee, Revenue's appeal being Tax Appeal No. 515 of 2018 concerning penalty arising out of the same judgment of the Tribunal came to be dismissed by this Court on 11th June 2018“. SLP of the revenue dismissed. - PR. CIT V/s NATIONAL DAIRY DEVELOPMENT BOARD - [2020] 270 TAXMAN 006 (SC)

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