In penalty proceedings, assessee can always show that finding recorded in quantum proceedings is neither reliable nor sufficient to impose penalty

RELEVANT PARAGRAPH

On careful consideration of relevant facts, I am of the view that important fact stated by the assessee in his reply to penalty notice has not been considered in accordance with law.

The revenue authority and the Tribunal in the quantum proceedings proceeded mainly on a presumption that the payment was made through account payee cheque, decided the issue against the assessee and the expenditure claimed was disallowed and added to the in

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