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On due consideration of the aforesaid, it cannot be said that learned ITAT has not appreciated the evidence of the Assessing Officer and the order passed by the Appellate Authority. In the case in hand, the return was revised much prior to the date of issuance of notice under Section 153-C of the Act. The Assessing Officer has no-where recorded his satisfaction to the fact that the assessee has concealed the particulars of income or furnished any inaccurate particulars of such income. Thus, we are of the view that there is no illegality in the order passed by the learned ITAT nor any substantial question of law is arising in this appeal. The income tax appeal filed by the Revenue has no merit and is accordingly, dismissed.

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Section 153C & 271(1)(c) of the Income Tax Act, 1961 — Penalty — Concealment of income— Return having been revised much prior to the date of issuance of the notice under section 153C and the AO having nowhere recorded his satisfaction that the assessee had concealed particulars of income or furnished any inaccurate particulars of such income. there was no illegality in the order of the Tribunal to the effect that there was neither Concealment of income nor furnishing of any inaccurate particulars thereof and no penalty under section 271(1)(c) was leviable — Principal Commissioner of income tax vs. Smt. Prabhjot Kaur Chabra [2019] 419 ITR 94 (MP)  

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