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Whether the Appellate Tribunal has erred in law and on facts in upholding the order of the CIT(A) deleting the penalty of Rs. 6,93,70,500/on account of on money receipts offered for taxation after being detected by the department as a result of survey action u/s.133A?

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Sec. 271(1)(c) of Income Tax Act, 1961 - Penalty - Revenue filed Tax Appeal against the impugned order of the Tribunal in deleting the penalty of Rs. 6,93,70,500/on account of on money receipts offered for taxation after being detected by the department as a result of survey action u/s.133A. High Court dismissed the Tax appeal of the revenue holding that ”the Tribunal proceeded on the principle of law that when the assessee disclosed the amount during the survey action under Section 133A and the same is honoured by filing the return of income, there cannot be any order of penalty under Section 271(1)(c) of the Act, 1961“. - PR. CIT V/s YAMUNAJI CORPORATION - [2020] 424 ITR 369 (GUJ)

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