The   AO levied penalty under s. 270A(a) by treating 40 per cent of the donations as anonymous donations on the ground that the assessee-trust could not discharge the burden cast on it to establish the identity and genuineness of the donors at the time of assessment. On appeal the Tribunal held that the assessee contended that  they are  in a position to produce evidence to the satisfaction of the AO regarding the identity and genuineness of the donors, the issue is restored to the AO with a direction to give one more opportunity to the assessee. (AY. 2017-18)