Penalty u/s 271(1)(c) cannot be levied for mere Assessment of Income at higher Percentage

ITAT Ahmedabad held in Sohan Builders Vs ACIT that if the AO had assessed the income of the assessee at some higher percentage than what the assessee had already shown in the computation then it would not amount to the concealment of income, so penalty u/s 271(1)(c) could not be levied provided there was not any additional material in the hands of revenue which could prove the concealment of income. As the assessee had already been assessed at higher percentage which

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