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2018 (6) TMI 65 - AT - Income TaxPenalty u/s 271AAA - inability to explain certain seized documents - Held that:- When the assessee has failed to specify the manner and substantiate the manner in which the undisclosed income was derived rather embark upon the mercy plea that he is making surrender to buy peace of mind and avoid litigation, he is not entitled for benefit of section 271AAA(2). Following the decision in case cited as Pr.CIT vs. Smt. Ritu Singal (2018 (3) TMI 593 - DELHI HIGH COURT) we are of the considered view that CIT (A) has erred in deleting the penalty u/s 271AAA, hence appeal filed by the Revenue is hereby allowed.
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