ssessee has shown all the expenses in the Profit & Loss account and there is no dispute about the particulars provided in the books of accounts nor the Ld. A.O has rejected the book results since no such finding is appearing in the penalty order as well as appellate order. There is no mandatory rule that for earning exempt income assessee has to incur any expenditure. It is only when the Ld. A.O is satisfied about the type and amount of expenses which have been incurred specifically for earning the exempt income and has been debited to Profit & Loss account for claiming expense against the revenue liable to be taxed. In the instantcasethe disallowance u/s 14A is on estimated basis made proportionately out of the finance charges. There is nocaseof concealment of particulars of income or furnishing of inaccurate particulars of income since the amount has been duly debited as expenses in Profit & Loss account. Since no bonafide intention or mensura on the part of the assessee is appearing on the face of the record placed before us, we are of the considered view that Ld. A.O was not justified in levying the penalty u/s 271(1)(c) of the Act at Rs. 1,03,870/-. Therefore in the given facts and circumstances of thecasewe set aside the finding of Ld. CIT(A) and delete the penalty of Rs. 1,03,870/- levied u/s 271(1)(c) of the Act