Penalty for concealment can not be imposed automatically for disallowance of deduction

RELEVANT PARAGRAPH

9. Part A of the Explanation to section 271(1)(c) provides that if assessee fails to offer an explanation or offers and explanation which is found by the Assessing Officer or the Commissioner (Appeals) or the Commissioner to be false. This explanation can therefore, be applied only where the assessee has either not offered any Explanation or where he has offered any Explanation, the same found to be false by

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