Tribunal held that the said issue was debatable and assessee was unaware of the decision of Apex Court on the said issue while filing return of income pursuant to notice under section.  148 of the Act.  However, assessee accepted the addition and paid taxes as well as interest on the same pursuant to decision of Apex Court.  Thus, it does not amount to concealment of particulars of income and furnishing inaccurate particulars when all necessary details were already furnished by assessee at the time of filing original return.  At the most assessee has put forth a wrong claim at the time of filing return pursuant to reopening under Section 148 of the Act and has never concealed the particulars of income or furnished inaccurate.  Thus, Tribunal relying on previous year’s decision in assessee’s own case deleted penalty.  (AY.  2006-07)