Allowing the appeal of the assesse the Tribunal held that initiation of penalty on one ground and levy of penalty on another ground is impermissible in law. The AO had issued a notice u/s 271(1)(c) on the grounds of ‘furnishing inaccurate particulars of income’. The penalty order passed by the AO was on the grounds of ‘concealing particulars of income’. This was impermissible in law. Followed CIT v Samson Perinchery (.2017) ) 392 ITR 4 ( Bom) (HC) Tata Communications Ltd v DCIT in ITA. No. 3108/M/2016 dt 21/02/2018. ( Mum) (Trib) (ITA.No. 515/Mum/2016/514 & 513 dt 19.12.2018)