Penalty u/s 271(1)(c) not justified; no concealment or inaccurate particulars by assessee. Exemption denial due to opinion change.

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....Penalty levied u/s. 271(1)(c) - The assessee had not concealed any income or furnished inaccurate particulars of income. The exemption u/s. 11 of the Act was denied to the assessee on a mere change of opinion - No penalty....