Dismissing the appeal of the Revenue the Court held that the penalty notice did not indicate which of the two limbs of S. 271(1)(c), i.e., concealment of income or furnishing of inaccurate particulars of income, was triggered in assessee’s case. The other issue which was ruled in favour of the assessee in prior years and reversal of  trend happened only when in the High Court ruled differently. Held, it was a debatable issue and no penalty could be levied. Order of Tribunal is affirmed. (AY. 2011-12)