Tribunal held that the  sections concerning additions are deeming provisions. In case of deeming provisions there is no option provided in the statute except to make adjustment as per figures derived from deeming section vis-à-vis figures disclosed by the Assessee. This being the case, case of the assessee does not fall in the category of under reporting of the income/income concealment. Penalty initiated is not only erroneous but also arbitrary and bereft of any reason as no limb has been specified for under reporting or misreporting of income for initiating penalty proceedings. (AY. 2018-19)