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2023 (3) TMI 1463 - HC - Income TaxDelay of 3270 days in re-filing the appeal - reasons given in the application is that there were certain objections and to remove those objections, sometime was taken to arrange relevant documents. The applicant had to consult various lawyers at Muktsar and after March 2020 on account of lock down, he was not able to consult the lawyers and in this backdrop, delay occured - Penalty u/s 271(1)(c) imposed as income surrender in the revised return of the income, after detection of concealment by the Department as a result of search of incriminating documents in the course of search and seizure operations HELD THAT:- The Tribunal, while dismissing the appeal of the appellant, had taken into consideration the judgments in the case of G.C. Aggarwal Vs. CIT [1990 (9) TMI 2 - SUPREME COURT] and Allahabad High Court in Mool Chand Mahesh Chand vs. CIT [1978 (3) TMI 65 - ALLAHABAD HIGH COURT] on the proposition that disclosure was made by the assessee in the revised return in response to 148(A) of the Act after search operation and in the revised returns, the assessee disclosed much larger incomes without justification than those disclosed in the original returns. The revised returns had been filed with a view to avoid litigation and imposition of penalty was upheld. Hence, order passed by the Tribunal does not require any interference as no substantial question of law arises in this appeal. The appeal is being dismissed on the ground of delay of 3270 days in refiling the appeal as well as on merits.
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