Failure to allot shares after collection of sum from applicants due to Govt.’s restriction won’t att

IT : Where assessee, a Sahkari mill, deducted certain amount from purchase price given to farmers on ground that such collection would be utilized for issuance of shares, in view of fact that shares could not be issued subsequently as State Government did not give requisite permission, it could not be regarded as a case of furnishing inaccurate particulars of income so as to impose penalty under section 271(1)(c)