Penalty for Wrong Set-Off Loss Claim Contested; No Evidence of Income Concealment or Inaccurate Details u/s 271(1)(c.

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....Penalty u/s 271(1)(c) - wrong claim of set off loss - explanation was not found false - no iota of evidence of concealment of any fact relating to particulars of income or furnishing of inaccurate particulars of income - Merely because the assessee had claimed the expenditure, which was not accepted or was not acceptable to the revenue, that by itself would not, attract the penalty u/s 271(1)(c)....