Penalty u/s 271(1)(c) can not be levied on ground of disallowance of deduction u/s 80HHC of IT Act, 1961

RELEVANT PARAGRAPH 12. Section 271(1)(c) provides that if the AO or the Commissioner (Appeals) or the Commissioner, in the course of proceedings in this Act is satisfied that any person has concealed the particulars of his income or furnish inaccurate particulars of income, he may direct that such person shall pay by way of penalty a sum which shall not be less than but which shall not exceed three times the amount of tax sought to be evaded by a reason of the concealment of particulars of his income. Explanation 1 to section 271(1)(c) provides that where in respect of any facts material to th...