Penalty u/s 271(1)(c) Not Imposed Due to Lack of Evidence Beyond Section 132(4) Statement in Tax Discrepancy Case.

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....Penalty u/s 271(1)(c) - difference of income in the return filed u/s.139(1) and 153A - there was no such allegation that of assessee was found to be the owner of any money, bullion, jewellery or other valuable article or thing or any income based on any entry in any books of account or other documents or transactions, either in the assessment or penalty or the CIT (A) order - no penalty 271 (1) (c) r.w. the explanation 5A merely on the basis of the statement u/s 132(4)....