Penalty Proceedings u/s 271(1)(c) Require Evidence, Not Just Upheld Additions by CIT(A.

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....Merely because additions made by the AO have been partially upheld by the CIT (A), would not confer the ground to initiate proceedings u/s 271(1)(c) of the Act of imposition of penalty, unless it is found that there is concealment of material facts, or furnishing of inaccurate particulars.....