No concealment penalty on mere TP adjustment if such issue was of debatable nature

IT/ILT: Where TPO determined ALP of international transaction at a higher amount as against disclosed by assessee and thereupon Assessing Officer made addition in income of assessee and also imposed penalty under section 271(1)(c) on basis of impugned addition, since issues on basis of which ALP shown by assessee had been rejected were debatable, they could not be said to be leading to concealment of income