Penalty u/s 271(1)(c) - non disclosure of capital gain on sale...

Penalty u/s 271(1)(c) - non disclosure of capital gain on sale of land in the income tax return - Sale consideration by applying the provisions of section 50C (i.e deeming fiction) - It is an admitted fact that there cannot be any penalty on the profit calculated for the assessee based on deeming section/fiction. - the revenue is not expected to derive any benefit out of the ignorance of the assessee. - there was no deliberate act on part of the assessee to conceal/furnish inaccurate particulars of income - No penalty - AT