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The provisions of appeal would also applicable in any proceedings initiated under Section 43 of the Act,which empowers the tax officer to initiate proceedings of imposition of penalty on account of failure to furnish any incorrect particulars about the asset including financial interest in any entity located outside India.

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Section 6 of the Income-tax Act, 1961—Penalty—THOMAS MATHEW vs. ITO.[2020] 25 ITCD Online 103 (KER)