Taxpayer's Honest Mistake: No Penalty u/s 271(1)(c) for Missing Interest in Capital Account.

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....Penalty u/s 271(1)(c) - A mere bonafide omission on the part of the assessee to account for the interest portion of the refund (which though had duly been reflected in his ‘Capital account’), would though have justified an addition to the said extent, however, a levy of penalty u/s 271(1)(c) merely for the said bonafide mistake would be totally unjustified.....