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ITAT addressed penalty under the Income-tax regime where an assessee, during search proceedings, admitted undisclosed income, explained the manner and source of accrual, and included the disclosure in the return with taxes and interest paid; the assessing officer and appellate authority acknowledged the disclosure. Applying the principle that a voluntary, explained disclosure during search accepted by revenue officers and regularised by return and tax payment negates penal liability, the tribunal found the statutory criteria satisfied and set aside the penalty, allowing the appeal.
ITAT addressed penalty under the Income-tax regime where an assessee, during search proceedings, admitted undisclosed income, explained the manner and source of accrual, and included the disclosure in the return with taxes and interest paid; the assessing officer and appellate authority acknowledged the disclosure. Applying the principle that a voluntary, explained disclosure during search accepted by revenue officers and regularised by return and tax payment negates penal liability, the tribunal found the statutory criteria satisfied and set aside the penalty, allowing the appeal.
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