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2012 (11) TMI 226 - ITAT, DELHIPenalty levied u/s 271(1)(c) against income from undisclosed sources as bogus gift – assessee before CIT(A) has surrendered the above amounts on the condition that no penalty should be imposed. – Held that:- assessee has submitted various documents in support of the gifts. It is not the case of the Revenue that the documents submitted in this regard are false. It is also a fact that during the appellate proceedings the assessee has himself agreed to surrender the above amounts. Under the circumstances, in our considered opinion, when the Revenue has not been able to find any fault in the documents submitted by the assessee in this regard, in our considered opinion, the penalty u/s. 271(1)(c) is not justified. - Decision in favour of assessee.
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