Disclosure of income detected during a survey that is recorded...

Disclosure of income detected during a survey that is recorded in books, included in the return and accepted in assessment negates the foundation for imposing a penalty under section 271(1)(c); the tribunal concluded there was no concealment or furnishing of inaccurate particulars where the assessing officer did not treat the amounts as unexplained credits or make separate additions and only made limited disallowances, and therefore deletion of the penalty was upheld as a matter of law and fact.