Each and every addition cannot be base for levy of penalty u/s. 271(1)(c): ITAT Surat

Dineshchandra Dudhwala Vs ITO (ITAT Surat) ITAT Surat held that each and every addition cannot be a basis for levying a penalty under section 271(1)(c) of the Income Tax Act. There has to be deliberate furnishing of inaccurate particulars or concealed income for levy of penalty. Accordingly, appeal allowed and penalty set aside. Facts- The case of assessee was reopened u/s. 147 and notice u/s. 148 dated 27.03.2018 was served upon the assessee. In response to notice u/s. 148, the assessee filed return of income declaring income of Rs.12,31,590/- and assessment was completed by making a small ad...