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2019 (5) TMI 1384 - AT - Income TaxRectification u/s 254 - Penalty u/s 271(1)(c) - unexplained investment in property - concealment and furnishing of inaccurate particulars in the belated return filed against the notice u/s 153A - HELD THAT:- The assessee did not offer any credible and cogent explanation for not offering the income in the form of unexplained investment in property pertaining to previous years ending before the search and such unexplained investment came into light only during the course of search operation and thus, tantamount to concealment of particulars of income within the meaning of Explanation 5 to section 271(1)(c). Moreover, the assessee had no valid reason for concealment and furnishing of inaccurate particulars in the belated return filed against the notice u/s 153A . In the absence, of any valid reason for not filing the return of income within the time stipulated u/s 139 or declaring complete particulars of income in the belated return filed by the assessee, the penalty levied u/s 271(1)(c) was sustained by the Tribunal. While adjudicating the appeal, the Tribunal has considered all the grounds relating the effective ground raised by the assessee. In view of the above, we find no merit in the miscellaneous petition filed by the assessee.
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