No section 271(1)(c) Penalty if AO fails to specify inaccurate particulars of income

Rajendra Venkat Reddy Vs DCIT (ITAT Pune)

The issue in the present appeal relates to the levy of penalty u/s 271(1)(c) of the Act. The Assessing Officer sought to levy penalty in respect of addition of Rs.15,00,000/- being unexplained cash deposits in the bank accounts held by the appellant. The addition was purportedly made u/s 69 or section 69A of the Act. Merely because, the Assessing Officer made addition does not lead to conclusion that the appellant is guilty of furnishing inaccurate particulars of income. The Assessing Officer had not rendered an

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