TMI Blog2023 (3) TMI 1463X X X X Extracts X X X X X X X X Extracts X X X X ..... me 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 do ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 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. - Hon'ble Ms. Justice Ritu Bahri And Hon'ble Mrs. Justice Manisha Batra For the Applicant/Petitioner : Mr. Divya Suri, Advocate with Ms. Sameeksha Gupta, Advocate ORDER RITU BAHRI, J. (ORAL). 1. CM-7245-CII-2022 is an applicati ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed 15.06.2011 passed by the CIT(A) whereby penalty under 271(1)(c) of the Act had been imposed and upheld by the CIT(A). 4. The assessee had concealed the income for the assessment years under reference and he had not disclosed the surrender made for the assessment years in the original returns of the income under reference. In response to notice under Section 153A of the Act, it is found to be a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e 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. 6. Hence, order dated 14.09.2012 (Annexure A-4) passed by the Tribunal does not require any interference as no ..... X X X X Extracts X X X X X X X X Extracts X X X X
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