AO couldn’t levy penalty by taxing trial run receipts on incomplete projects as they were capital re

IT : Where assessee, engaged in scientific research activities, consistently followed practice of Capitalising amount received during trial run period which was duly disclosed in its balance sheet, AO could not pass a penalty order under section 271(1)(c) taking a view that said amount being result of assessee's regular business activity, was liable to be added to its taxable income