Penalty u/s 271(1)(c) not leviable in absence of concealment of particulars of income

Manoj Mittal Vs DCIT (ITAT Delhi) ITAT Delhi held that penalty under section 271(1)(c) of the Income Tax Act not leviable since there is no concealment of particulars of income by the assessee. Facts- The assessee is an individual filed his return of income on 30.09.2010 declaring income of Rs.47,28,153/-. The assessment was completed u/s 143(3) of the Act making an addition of Rs.18,42,000/- on account of loan received by the assessee which was treated as deemed dividend u/s 2(22)(e) of the Act. The assessee preferred an appeal before the Ld.CIT(A) and also the Tribunal. The Tribunal restrict...