TMI Blog2014 (10) TMI 867X X X X Extracts X X X X X X X X Extracts X X X X ..... n sale of land and certain other investment, and has disclosed an amount in its return of income filed in response to the notice under section 153A of the Act in the name of the assessee or his family members. We find that merely because the explanation of the assessee with regard to the acquisition of some part of the jewellery not accepted by the taxing authorities, it does not follow that the a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... irected against the order of the CIT(A). 2. The only ground of the appeal of the assessee is as under: 1. On the facts and in the circumstances of the case as well as law on the subject, the learned CIT(A) has erred in confirming the action of the AO in levying penalty of ₹ 97,113/- u/s.271(1)(c) of the IT Act, 1961 3. The learned counsel of the assessee submitted that the only ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ion, and merely because it was not accepted during the assessment proceedings, it does not mean that the assessee is guilty for concealment of income or filing of inaccurate particulars of income. He submitted that the explanation of the assessee was bona fide. 4. The learned DR has opposed the submissions of the learned counsel for the assessee. He submitted that the disclosure was made by the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... eturn of income filed in response to the notice under section 153A of the Act in the name of the assessee or his family members. We find that merely because the explanation of the assessee with regard to the acquisition of some part of the jewellery not accepted by the taxing authorities, it does not follow that the assessee was guilty of concealment of income or filing of inaccurate particulars o ..... X X X X Extracts X X X X X X X X Extracts X X X X
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