Penalty Proceedings Limited to Initial Issues in Section 271(1)(c) of Income Tax Act.

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....Penalty levied u/s 271(1)(c) - Scope of penalty proceedings u/s 271(1)(c) of IT Act cannot be widened later to include within its scope such additions which were not sought to be covered within the scope of penalty U/s 271(1)(c) of IT Act, at the time when penalty proceedings were initiated and assessment order was passed. - AT....