Tribunal held that that the disallowance of excess brought forward losses pursuant to MAP order  while giving effect the   to the MAP resolution in assessee’s case for asst. yr. 2012-13 which resulted in change in the loss carried forward for set off in the subsequent years including the relevant asst. yr. 2016-17. Merely because the assessment order was passed on the basis of addition/disallowances and the assessee agreed to the addition and already paid the taxes along with the interest way before the initiation of the assessment proceedings, it could not be inferred that the assessee furnished inaccurate particulars of income. The explanation was a not found to be false. On the contrary it was held to be bona fide. Levy of penalty is deleted. (AY. 2016-17)