Penalty U/s. 271(1)(c) can not be imposed on the basis of routine & general presumptions

RELEVANT PARAGRAPH 6.1 The proceedings under section 271(1) (C) can be initiated only if the A.O or the first Appellate authority is satisfied in the course of any proceedings under the Act. If he is satisfied as per clause (c) that any person has concealed the particulars of his income or has furnished inaccurate particulars of such income, he may direct that such person shall pay by way of penalty the sum mentioned in sub-clause (iii) of clause (c). The expression used in clause (c) is ‘has concealed the particulars of his income’ or ‘furnished inaccurate particulars of suc...