Section 271(1)(c) Penalty Requires Evidence of Concealment, Not Just Income Additions in Tax Proceedings.

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....Penalty u/s 271(1)(c) - Any addition/disallowances made during the quantum proceedings does not automatically justify the levy of the penalty under section 271(1)(c) - Besides the element of income added the quantum proceedings, there must be some material/circumstantial evidences leading to the reasonable conclusion that there was conscious concealment or the act of furnishing of inaccurate particulars on the part of the assessee.....