Penalty u/s 271(1)(c) - surrendered of the income - The assessee...

Penalty u/s 271(1)(c) - surrendered of the income - The assessee has nowhere disputed the said surrender being made under coercive circumstances or under compulsion. Even otherwise, the surrender is not without any basis but the entry of share application money is very much in existence which was accepted by the assessee as accommodation entries. Therefore, there is no substance or merit in the contention of the Ld. AR that surrender was made by the assessee to buy peace of mind. - AT