36(1)(va) of the Act of ₹33,33,704/- on account of delayed\npayment of PF and ESI and the penalty was initiated for concealment\nof income. The Id. AO accordingly imposed penalty of ₹1 ,47 ,93,284/-\nbeing 100% of the tax sought to be evaded.\n8.\nThe Id. CIT (A) in the appellate proceedings affirmed the order