Dismissing the appeal the Court held that that the finding of fact recorded by the Assessing Officer would clearly show that as early as June 29, 2000 there was an agreement with third parties for converting the land into housing plots by filling sand, levelling, forming roads, carrying out other developmental activities. Therefore, when the penalty proceedings were initiated, the Assessing Officer was fully justified in holding that the assessee was consciously aware of the real position and knowingly furnished inaccurate particulars of income in the revised return. The assessee was not an individual, but a company, which was an association of persons consisting of other corporate giants. Therefore the levy of penalty was justified. (AY. 2001-02  2002-03)