If assessee failes to furnish the complete facts relating to the claim before the Assessing Officer then penalty u/s. 271(1)(c) can be imposed

Kanchenjunga Advertising P. Ltd. Vs. CIT (Delhi HC)- It is a well settled position that assessment proceedings and penalty proceedings are different in nature and that the findings given in the assessment proceedings, though may constitute good evidence, cannot constitute conclusive evidence for the purposes of levying penalty. (please see CIT Vs. Anwar Ali (1970) 76 ITR 696, CIT v. Khoday Eswarsa and Sons ( 1970) 83 ITR 369, and Anantharam Veerasinghaiam & Co. Vs. CIT (1980)123 ITR 457). It is also well settled that for the purpose of Section 271(1)(c) of the Act, the mere making of an in...