Penalty u/s 271(1)(c) cannot be levied for mere non acceptance of explanation furnished by the assessee

Issue -During the course of search certain valuables including jewellery was found and the assessee has filed detailed explanation regarding the source of acquisition of jewellery. The assessee has explained that out of the jewellery found, some part belongs to the wife of the assessee, and some part thereof was gifted by the mother of the assessee to the wife of the However, the explanation of the assessee was not fully accepted and out of jewellery weighing 4492.5 grams found at the time of search, the jewellery weighing 783.15 grams was treated as income from undisclosed source by the AO. H...