INCOME TAX : Burden of proof in penalty proceedings vary from that in assessment proceedings and findings in assessment proceedings would not automatically be adopted in penalty proceedings; in penalty proceedings revenue authorities have to arrive at independent finding related to 'concealment of income' or 'inaccurate particular'
from www.taxmann.com Latest Case Laws https://www.taxmann.com/topstories/101010000000193127/penalty-to-be-levied-only-when-it-is-proved-that-‘income-concealment’-or-‘inaccurate-particular’-was-furnished-hc.aspx
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