Penalty u/s 271(1)(c) Not Justified Without Proof of Concealment or Inaccurate Details by Taxpayer.

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....Penalty levied u/s 271(1)(c) - merely on the basis of additions, AO would not ipso facto lead to the conclusion that the assessee has concealed the particulars of income or furnished inaccurate particulars of income when there is no such allegation by the AO that the assessee has not furnished all relevant particulars and details in respect of this claim - AT....