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ITAT held that penalty u/s 271(1)(c) is not sustainable when assessee voluntarily revised ITR before notice u/s 153A and the additional income was accepted by AO without specific linkage to seized materials. The tribunal followed precedent establishing that revised return post-search takes place of original return, and higher income declaration does not automatically attract penalty. Appeal by assessee allowed, penalty deleted.
ITAT held that penalty u/s 271(1)(c) is not sustainable when assessee voluntarily revised ITR before notice u/s 153A and the additional income was accepted by AO without specific linkage to seized materials. The tribunal followed precedent establishing that revised return post-search takes place of original return, and higher income declaration does not automatically attract penalty. Appeal by assessee allowed, penalty deleted.
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