Confirmation of addition by tribunal does not mean concealment of income or inaccurate furnishing of particulars of income

 RELEVANT PARAGRAPH
As per the provisions of section 271(1)(c) the penalty under this section is leviable if the AO is satisfied in the course of any proceeding under this Act that any person has concealed the particulars of his income or furnished inaccurate particulars of such income.

The penalty proceedings and the assessment proceedings both are different. Explanation 1to section 271(1)(c) in respect of any fact relating to the computation of total in

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