Tribunal held that the penalty was initiated under both limbs of section 271(1)(c) of the Income-tax Act, 1961 whereas in the assessment order the penalty was only initiated for concealment of income. There was an ambiguity in the mind of the Assessing Officer while imposing penalty. Whenever penalty is to be imposed, the assessee must have a chance of self-defence, under the principles of natural justice and in this, since satisfaction was not recorded by the Assessing Officer it was obvious that the assessee was unable to prepare her defence whether penalty was imposed for concealment or furnishing of inaccurate particulars of income. In such circumstances, there could not be any imposition of penalty under section 271(1)(c) .Accordingly the penalty was cancelled.