ITAT deletes penalty on Failure of AO to mention specific limb of section 271(1)(c); Penalty cannot be imposed for mere valuation difference

Penalty U/s. 271(c) Addition for difference on account of method of valuation of Closing Stock without any intention to  to conceal income or furnishing of inaccurate particulars of income not justified A perusal of the penalty order reveals that the AO has rejected the contentions of the assessee on the basis that the addition made on account of difference in valuation closing stock and wrong claim of expenses is amounts to furnishing of inaccurate particulars of income. However, such difference on account of method of valuation does not lead that there was conscious or intention to conceal ...