https://www.scconline.com/blog/post/2018/07/11/penalty-under-section-2711c-of-income-tax-act-is-not-automatic-intentional-wrongdoing-by-the-assessee-has-to-be-established/
Penalty under Section 271(1)(c) of Income Tax Act is not automatic, intentional wrongdoing by the assessee has to be established