Held that the assessee had disclosed the factum of conversion of capital asset, i.e., land into stock-in-trade, during the survey under s. 133A, which was conducted prior to the due date of filing the return and paid a substantial amount of advance tax and TDS. Penalty under s. 271(1)(c) is not leviable, more so when the income returned by the assessee has been accepted without any variation. (AY.2016-17)