Where pursuant to survey proceedings, the assessee had voluntarily offered certain income to tax, the same would not be liable to penalty. These facts are different from a case where income is offered in a revised return of income after the addition is discovered by the Assessing Officer. ( AY. 2013-14 )
PCIT v. Shreedhar Associates (2022) 440 ITR 547 (Guj) ( HC)
S. 271(1)(c) : Penalty – Concealment –On money – Survey – Income voluntarily offered- Deletion of penalty is held to be justified [ S. 131(IA), 133A]