No penalty for addition under section 56(2)(x) due to deeming fiction

Dipakkumar Ishwarlal Panchal Vs ITO (ITAT Ahmedabad) Admittedly the concealment/furnishing of inaccurate particulars of income, for which act penalty under section 271(1)(c) in the present case has been levied, related to the income added as per the provisions of section 56(2)(x) of the Act. More particularly on account of the fact that actual consideration paid for purchase of a property was less than its stamp duty value. It is not the case of the Revenue that the assessee was actually found to have paid any amount over and above actual purchase price of the asset. Moreover section 56(2)(x) ...