Tribunal held that it was only a case of opinion on the part of the Assessing Officer that the assessee had diverted interest bearing funds to interest-free advances ignoring the fact that the assessee had huge interest-free reserves. The penalty was imposed by calculating notional interest on interest-free advances. The assessee had not concealed any particulars of income. Even if the assessee had made a wrong claim a mere wrong claim could not amount to furnishing of inaccurate particulars of income or concealment of income. The penalty was not sustainable.( AY.2011-12)