Penalty u/s 271(1)(c) Unjustified Due to Lack of Evidence; Assessee's Explanation Not Proven False by AO.

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....Penalty u/s 271(1)(c) - Assessee has failed to explain the source with support of evidence, but his explanation was not found to be false. The lapse committed at his end may authorise the AO to make addition, but that will not authorise the AO to visit the assessee with penalty. The explanation of the assessee ought to have been found as false by the AO. Nothing that sort of exercise has been made or any material discernible from the record. - AT....