Penalty cannot be levied in respect of an addition not having been made in quantum assessment

In this Question arose for consideration was whether penalty under section 271(1)(c) of Income Tax Act, 1961 could be levied in respect of an addition not having been made in quantum/assessment proceedings and it was held that Imposition of penalty proceedings under section 271(1)(c) is strictly circumscribed to addition which has been made/confirmed in the assessment/quantum proceedings. Hence, addition not having been made in the assessment or in quantum proceedings by any appellate authority, could not be roped in penalty proceedings either by AO or CIT(A) in

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