The AO also initiated penalty proceedings under Section 271(1)(c) for providing inaccurate particulars and concealing income. The AO had issued a show cause notice under Section 274 read with Section 271(1)(c) on 17-12-2018 and imposed a 100% penalty on the tax evaded, as the assessee's explanation was not accepted. The assessee appealed the penalty order to the CIT(A), arguing that the deduction under Section 80P(2)(i) should have been allowed in the quantum appeal, citing the State Bank of India case and the Reliance Petroproducts Ltd. case. The CIT(A) rejected the appeal, confirming the penalty and stating that the set-off of brought forward losses was incorrect due to missing returns for AY 2004-05 to AY 2008-09. The CIT(A) stated that the decision in Reliance Petroproducts Ltd. case is inapplicable. The assessee being aggrieved by the decision of the CIT(A) appealed before the tribunal.