Assessing Officer cannot impose penalty u/s. 271(1)(c) on the basis of routine and general presumptions

RELEVANT PARAGRAPH 7.3 Now coming to the merits of the case, we noticed that the AO levied penalty u/s 271(l)(c) on the ground that the assessee has filed inaccurate particulars of income. What is inaccurate particulars of income within the meaning of provisions of section 271(l)(c) of the Act has been discussed in details by the ITAT Mumbai Bench in the case of Mimosa Investment Co. Pvt. Ltd, in ITA No. 2983/Mum/07 for AY 2004-05 order dated 15.01.09. The said order has been followed by the ITAT in the case of ITO Vs. GACL Ltd. in ITA No. 6528/M/05 vide order dated 19.03.2009, the decision ci...