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Besides the element of income added the quantum proceedings, there must be some material/circumstantial evidences leading to the reasonable conclusion that there was conscious concealment or the act of furnishing of inaccurate particulars on the part of the assessee.

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Sec. 271(l)(c) of Income Tax Act, 1961 - Penalty - Any addition/disallowances made during the quantum proceedings does not automatically justify the levy of the penalty under section 271(1)(c) of the Act. Besides the element of income added the quantum proceedings, there must be some material/circumstantial evidences leading to the reasonable conclusion that there was conscious concealment or the act of furnishing of inaccurate particulars on the part of the assessee. Hence, the penalty levied under section 271(1)(c) of the Act deleted.—JAGDISHBHAIMADHUBHAI PATEL vs. Asstt. CIt.[2020] 26 ITCD Online 021 (ITAT-AHMEDABAD)

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