Section 271(1)(c) Penalty not leviable if No specific charge framed against assessee

Mahaveerchand Jain Vs DCIT (ITAT Chennai) Facts- The assessee being resident individual was assessed u/s 143(3) r.w.s. 147 of the Act wherein the income was assessed at Rs.20.47 Lacs after certain additions of unexplained cash deposits in the bank account of the assessee. The assessee was engaged in the business of auctioneering under the name ‘Kankaria Auctioneers’. Pursuant to search action on Shri Jaswant Chand Bhandari on 12.08.2004, it was found that the said group sold jewellery and diamonds through ‘Kankaria Auctioneers’. Accordingly, the assessee’s case was reopened wherein i...