No penalty u/s 271(1)(C), when the taxable income and tax remains the same after adjusting the addition due to concealment

Brief about the case The assessee was an apex marketing society in cooperative sector in West Bengal involved in the activities of marketing, procurement and distribution of fertilizer and other agricultural inputs like jute, paddy, seeds, and pesticides, etc. through various members, primary co-operative societies. The assessee has filed the return at an income of Rs.1,32,45,463/- on 03.11.2009. The assessment was completed on the returned income of Rs.1,32,45,460/- by making certain disallowances and allowing the set-off of the business loss for the assessment years 2003-04 and 2004-05. The ...