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2014 (8) TMI 873 - ITAT AHMEDABADPenalty u/s 271(1)(c) - Undisclosed bank accounts – Addition of peak credit – Held that:- The six bank accounts with reference to which addition was made by the AO were not disclosed by the assessee in its return of income - The source of deposit in the bank accounts could not be explained by the assessee - the addition of peak balance in the bank accounts cannot be held as an addition made merely on estimate basis without relevant materials – relying upon CIT Vs. Becharbhai P. Parmar [2012 (4) TMI 418 - GUJARAT HIGH COURT] - the disclosure of the other five undisclosed bank accounts by the assessee cannot be held as voluntary disclosure by the assessee – it came up because the Department already detected one undisclosed bank account which contained transfer entries of the remaining five undisclosed bank accounts – there was no reason to interfere with the orders – Decided against Assessee.
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