In the result, the penalty is directed to be deleted and appeal of the assessee is allowed
penalty imposed u/s 271(1)(c) is wrong, unwarranted, bad in law as the concealment of income and furnishing inaccurate particulars of income, are different defaults and they cannot be intermixed. 22. Now, coming to the other contention of the ld AR. The ld. AR of the assessee has submitted that there is no concealment or reporting of inaccurate particulars