IT : As per provisions of section 271(1)(c), what is material is the resultant addition to the taxable income of an assessee which may invite penalty under the relevant provisions of section 271(1)(c). Though the words used in the first part, i.e. charging provision are 'Particulars' of income, however, for levy of penalty it is not the 'Particulars' of income but rather the 'quantum of income itself, that is added to the taxable income of the assessee, is relevant for the purpose of calculation
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