Observation of Supreme Court in case of Union of India v. Dharamendra Textile Processors [2008] 174 Taxman 571 to effect that penalty under section 271(1)(c) is to provide remedy for loss of revenue cannot be viewed as an authority for proposition that a penalty under section 271(1)(c) is an automatic consequence of an addition being made to income of taxpayer, for reason that whether it is a civil liability or a criminal liability, penalty under section 271(1)(c) can only come into play when conditions laid down under that section are satisfied - Kanbay Software India (P.) Ltd. v. Deputy Commissioner of Income-tax - [2009] 31 SOT 153 (PUNE) [IT APPEAL NO. 300(PUNE) OF 2007]
