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In the result, the appeal is partly allowed
Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra
271(1)(c) then consequential notice under section 274 issued by the assessing officer to the assessee to afford him opportunity of hearing, was specifically a notice for penalty for concealment of particulars of income/undisclosed income and such a notice complied with principles of natural justice and was a valid notice under section 274 and the Tribunal had committed