Held, that quantum proceedings and penalty proceedings were independent and distinct proceedings and confirmation of an addition cannot on a standalone basis justify imposition or upholding of a penalty under section 271(1)(c) of the Act. Unless a specific exception is provided in the circular with respect to penalty, it could not be construed that penalty was to be treated at par with the quantum additions. Para 10(e) of the Central Board of Direct Taxes Circular No. 3 of 2018 (as amended on August 20, 2018), applied only to additions which were based on information received from external sources. The levy of penalty by no means could be construed as an addition within the meaning of para 10(e) of the circular. The appeal of the Revenue was covered by the Central Board of Direct Taxes Circular No. 17 of 2019, dated August 8, 2019, and was not maintainable. Appeal of Revenue was dismissed. Circular No 3 of 2018  (2018)  405 ITR  (St.) 29, as amended on 20-8-2018  [2018 407 ITR  (St.) 7, Circular No 17 of 2019  Dated 8-8-2019  [2019 416 ITR  (St.) 106. (AY. 2009-10)