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2008 (3) TMI 309 - GUJARAT HIGH COURT
Assessee filed revised return surrendering amount standing in names of family members – AO levied penalty on ground that revised returns had not been filed voluntarily but filed only after search and seizure - Admittedly some steps were taken by the Departmental authorities for finding out the concealment but no specific notice was issued by the Departmental authorities Thus, there was only a prima facie belief that the assessee has concealed his income – family members assessed on such income – held that there is no concealment – penalty not imposable u/s 271(1)(c)