Held that penalty, even if leviable, would be leviable only on so much of the additions as was upheld by the Tribunal in the quantum proceedings. Once the Assessing Officer has levied the higher penalty of two hundred per cent. of tax payable on the misreported income, the Assessing Officer has to bring the action or omission of the assessee within the scope of sub-section (9) of section 270A of the Act. He must establish that the ingredients mentioned in clauses (a) to (f) of sub-section (9) of section 270A of the Act exist. The Assessing Officer had failed to spell out how the assessee’s case fell within the ken of those clauses. Therefore, the levy of penalty could not be sustained. It is trite law that penalty provisions have to be strictly interpreted. The levy of penalty under section 270A of the Act suffered from the vice of non-application of mind and violated the principles of natural justice. The penalty  is  deleted.(AY.2017-18)