Penalty u/s 271(1)(c) not leviable on addition due to difference of opinion

Dinesh Kumar Agarwal Vs ACIT (ITAT Kolkata) ITAT Kolkata held that penalty u/s 271(1)(c) of the Income Tax Act not leviable as computation of income resulting into higher income is only a difference of opinion. Facts- Though the assessee has taken five grounds of appeal, but his grievances revolve around a single issue, namely ld. CIT(Appeals) has erred in confirming the penalty of Rs.1,65,780/-imposed by the ld. Assessing Officer under section 271(1)(c) of the Income Tax Act. Conclusion- A perusal of the penalty order would suggest that the ld. Assessing Officer has not recorded any categoric...