Tribunal held that AO computed the tax liability of the assessee under s. 115JB, penalty under s. 271(1)(c) is not attracted with reference to the additions made under the normal provisions; since the assessment year involved is 2012-13, which is prior to asst. yr. 2016-17 where from Expln. 4 to s. 271(1) is applicable, no penalty under s. 271(1)(c) could be imposed, even though the penalty proceedings were pending as on 1st April, 2016.  Followed, CIT v. Nalwa Sons Investments Ltd. (2010) 235 CTR 209 / 45 DTR 345 (Delhi)(HC).  (AY. 2012-13)