The assessee filed a return for the assessment year 2011-12, declaring an income and a capital gain, which was processed under Section 143(1). The Revenue suspected suppression of capital gains and issued a summons under Section 131 on 19.05.2014. A penalty notice was issued without specifying whether it was for concealment of income or furnishing inaccurate particulars, and the Assessing Authority imposed a penalty. the notice proposing penalty, that was issued to the respondent/assessee, was inherently defective, in that, it had not specified the particular ground on which the Revenue was proceeding against the assessee for the imposition of the penalty. The Explanation clearly envisages that where a satisfactory explanation has been offered by the assessee, well before the issuance of a notice to him under Section 148 and the admission of additional income made by the assessee has been accepted by the Revenue which completed the assessment under Section 143 read with Section 147 on that basis, the explanation offered by the assesee with regard to the differential income has to be been seen as accepted by the Revenue for the purposes of the Explanation under Section 271. Axiomatically, therefore, the said additional income cannot be treated as concealed income for the purposes of Section 271(1)(c).  (AY. 2011-12)