(1.) Appeal is admitted on the following substantial question of law : "Whether the mistake committed by counsel in advising the assessee and the assessee on such advice submitted return omitting a particular item to be shown in the return can be said to be an act committed by the assessee in concealing deliberately the item of income and thus is liable to penalty under s. 271(1)(c) of the IT Act - Issue notice. Steps to be taken within a week.