Section 271(1)(c) Penalty Applies Only for Concealed or Inaccurate Income Details, Not for Ad-Hoc Additions.

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....Penalty u/s 271(1)(c) - Penalty under section 271(1)(c) of the Act is leviable to be imposed only where the assessee has concealed its particulars of income or furnished inaccurate particulars. Action of making addition on ad-hoc basis does not result into imposition of penalty u/s. 271(1)(c) of the Act and hence cannot be termed as either concealment or furnishing of inaccurate particulars of income - AT....