Mistake in Penalty for Income Concealment u/s 271(1)(c) Can't be Rectified via Section 154 of Income Tax Act.

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....Rectification of mistake - Penalty u/s 271(1)(c) - Since the concealment of income referred to in 271(1)(c) of the Act is in respect of tax sought to be evaded is defined in Explanation 4 w.r.t. the income and the potential tax effect, the issue is required to be debated by long drawn process to decide the issue and cannot be adjudicated u/s 154 of the Act.....