The penalty proceeding under section 271(1)(c) read with explanation 1 of the said section of the Income Tax Act has been initiated during the course of assessment proceeding against the appellant. Subsequently, the said penalty proceeding was kept in abeyance because of the particular fact that the appeal against the decision of the AO was pending before the Ld. CIT(A). Thereafter, by and under an order dated 15.12.2004 the said appeal was dismissed by the Ld. CIT(A) confirming the addition made by the Ld. AO whereupon, an appeal has been preferred before the Income Tax Appellate Tribunal but the same was dismissed vide order dated 29.03.2016. As a result, of the dismissal of the appeal filed by the assessee against the order passed by the Ld. CIT(A) dated 15.12.2004 the said order attained finality and the penalty proceeding which was kept in abeyance got revived and was finalized by an order dated 27.11.2006 by levying penalty to the tune of Rs. 14,77,77,822/- under section 271(1)(c) of the Act on the ground of furnishing inaccurate particulars of income by the assessee which was, in turn, confirmed by the Ld. CIT(A). Hence, the instant appeal before Tribunal.