Allowing the appeal of the assessee the Tribunal held  that it was not the case of the Department that the assessee had concealed any income or expenditure but only that it had claimed the expenses as deferred revenue expenses whereas according to the Assessing Officer, the expenses had to be treated as capital expenses allowing the depreciation. It was not a case of concealment of income nor of furnishing of any inaccurate particulars but only of difference of opinion between the assessee and the Assessing Officer in respect of the treatment to be given to a particular expenditure. Further the assessee did not stand to gain much by this differential treatment also. The essential ingredients to attract the provisions under section 271(1)(c) of the Act did not exist in this case.( AY.2006-07)