The Tribunal held that the assessee's case falls within clause...

The Tribunal held that the assessee's case falls within clause (c) of Section 271AAB(1) as the admission made by the assessee was not honored in the return of income. Clauses (a) and (b) were not applicable. The Assessing Officer correctly invoked clause (c) and provided adequate opportunity of hearing to the assessee as per Section 274(1). The assessee did not offer any explanation against the impugned addition and merely pleaded to keep the proceedings in abeyance. The penalty order was within the time limit prescribed u/s 275(1). There was no violation of the principles of natural justice as adequate opportunity was provided. The income surrendered but not admitted would fall under the purview of undisclosed income. The assessee's appeal was dismissed.