2019 (1) TMI 998

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..... eedings u/s 271(1)(c) of the Act for concealing the particulars of income which is evident from page no. 5 of the assessment order dated 21.11.2011. However, the penalty was levied by the AO for furnishing of inaccurate particulars of income. Therefore, it is clear that the initiation of penalty proceedings were on different count then the levy of penalty. In that view of the matter, the penalty l .....

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..... was processed u/s 143(1) of the Act. Later on, the case was selected for scrutiny. The AO framed the assessment at an income of ₹ 9,40,690/- by making an addition of ₹ 6,00,000/- on account of deposits made in the saving bank account. 4. Being aggrieved the assessee carried the matter to the ld. CIT(A) who sustained the addition made by the AO. Thereafter, the AO levied the impugned .....

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..... e present case, it is an admitted fact that the AO initiated the penalty proceedings u/s 271(1)(c) of the Act for concealing the particulars of income which is evident from page no. 5 of the assessment order dated 21.11.2011. However, the penalty was levied by the AO for furnishing of inaccurate particulars of income. Therefore, it is clear that the initiation of penalty proceedings were on differ .....

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