Penalty u/s. 271(1)(c) untenable without concealment of income or furnishing of inaccurate particulars

Amitabha Sanyal Vs ITO (ITAT Kolkata) ITAT Kolkata held that imposition of penalty u/s. 271(1)(c) of the Income Tax Act untenable without concealment of particulars of income or for furnishing of inaccurate particulars. Accordingly, penalty deleted. Facts- Vide the present appeal, the appellant has mainly contested the imposition of penalty of ₹4,56,362/-, being without jurisdiction, illegal and invalid, bad in law, without recording proper satisfaction within the meaning of Section 271 of the Act and without appreciating that the amount of ₹22,95,849/-arising in the hands of the assessee ...