AO couldn't levy penalty for furnishing 'inaccurate' particulars by invoking Explanation 1 to sectio

IT: Where Assessing Officer levied penalty on assessee for furnishing inaccurate particulars of income by invoking Explanation 1 to section 271(1)(c), same could not be sustained as Explanation 1 is applicable in respect of particulars which have been concealed and not for furnishing inaccurate particulars of income