Dismissing the appeal of the High Court that in the absence of any specific finding of the AO or the CIT(A) that no reasonable cause has been shown by the assessee for not filing voluntary return, levy of penalty under S.. 18(1)(c) was not justified by invoking the deeming provision of Expln. 3 to S. 18(1). Order in Shanti Ramanand Sagar v. CIT (2017) 88 Taxmann.com 72 (Bom.)(HC) is distinguished. (AY. 1997-98, 1998-99)
CIT. v. Rajwanti Properties (P) Ltd. (2019) 310 CTR 113 / 181 DTR 1 (Mad.)(HC)
S. 18(1)(c) : Penalty-Concealment-In the absence of any proof to show that there was an attempt on the part of the assessee to conceal the particulars or to furnish inaccurate particulars, the levy of penalty was not justified by invoking the deeming provision of Expln. 3 to S. 18(1).