Assessee field his return of income and including additional income in its return under section 153A. Assessment under section 153A was completed and AO during the course of assessment proceedings held that assessee had shown additional income due to search. AO initiated penalty under section 271(1)(c) as the additional income was not declared in the return filed under section 139. Tribunal held that penalty levied under section 271(1)(c) was not sustainable in law as no specific charge was levied in penalty show cause notice. The High Court held that the ground mentioned in show cause notice would not satisfy the requirement of law, as notice was not specific. The High Court  placing reliance placed on the decisions of CIT v. Manjunatha Cotton Ginning Factory (2013) 359 ITR 565(Karn)(HC) and CIT v. SSA’s Emerald Meadows (2016) 242 Taman 180 (SC) held that the Tribunal was right in setting aside the order of penalty imposed by the AO. (AY. 2002-03 to  2007-08)