Court upholds penalty under Income-tax Act for non-disclosure, rejects claim under amnesty scheme.

The Court upheld the penalty imposed under section 271(1)(c) of the Income-tax Act for the assessment year 1983-84. The appellant's varying income declarations and failure to disclose a significant amount before detection by the authorities led to the penalty. Despite the appellant's claim of disclosure under an amnesty scheme, the Court determined that the penalty was justified as voluntary disclosure should precede detection. The appeal was dismissed, affirming the Tribunal's decision on the minimum penalty under the Act.

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Issues: Appeal against penalty levied under section 271(1)(c) of the Income-tax Act for the assessment year 1983-84.

Analysis:
1. The appellant filed three returns for the assessment year 1983-84, showing varying incomes.
2. The appellant initially declared an income of Rs. 17,563, later increased it to Rs. 96,200 after a search, and then further to Rs. 1,12,640.
3. Authorities found that the appellant did not voluntarily disclose the amount of Rs. 96,200 deposited in Syndicate Bank.
4. The appellant claimed to have disclosed the amount under an amnesty scheme, but it was after detection by the Department.
5. Voluntary disclosure to avoid penalty should be made before detection by the Department.
6. Since the appellant admitted the income only after detection, they cannot avoid penalty.
7. The penalty levied was the minimum under section 271(1)(c) of the Act.
8. The Court found no grounds to interfere with the Tribunal's order and dismissed the appeal.

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