2019 (2) TMI 127

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..... he interest thereof in the absence of any material on record to show the concealment of income, it cannot be inferred that the said addition is on account of concealment, so as to levy penalty under Section 271(1)(c) of the Act. We find no error in the order passed by the Tribunal especially when it is admitted that the decision in C.I.T. Vs. Manjunatha Cotton and Ginning Factory (2013 (7) TMI .....

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..... the satisfactorily to AO? ii. Whether Explanation 1 would come into play once no explanation is offered by the asessee and penalty become leviable? 2. Heard Ms.R.Hemalatha, learned Senior Standing Counsel appearing for the appellant and Mr.Vikram Vijayaraghavan, learned counsel appearing for the assessee. 3. The Tribunal by the impugned order set aside the penalty imposed on the assessee .....

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..... is on account of concealment, so as to levy penalty under Section 271(1)(c) of the Act. 5. We find no error in the order passed by the Tribunal especially when it is admitted that the decision in C.I.T. Vs. Manjunatha Cotton and Ginning Factory has attained finality. Thus, for the above reasons, the appeal filed by the Revenue is dismissed and the substantial substantial questions of law are a .....

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