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2016 (10) TMI 1071 - AT - Income TaxPenalty u/s 271AAA - surrender of unexplained/ undisclosed income found during the search conducted u/s 132 - manner of undisclosed income derived - Held that:- Department had not raised any specific query regarding the manner in which the undisclosed income had been derived. In absence of query about the manner in which the undisclosed income was derived and about its substantiation, it is our considered view that the AO was not justified in imposing penalty u/ s 271AAA specially, when the offered undisclosed income was accepted by the AO and the tax due thereon had been paid by the assessee. We draw our strength from the decision in the case of Neeraj Singal vs. ACIT [2013 (6) TMI 762 - ITAT DELHI] which is identical to the present case. - Decided in favour of assessee.
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