https://www.taxtmi.com/caselaws?id=269656 The Tribunal concluded that the penalty under Section 271(1)(c) was not justified. The key reasons included that the amounts in question were opening balances from previous years, not taxable in the current year, the surrender of income was not voluntary, and the AO did not conduct an independent inquiry during penalty proceedings. Additionally, assessment and penalty proceedings are distinct, and the penalty cannot be imposed solely based on the assessment order's findings. The appeal of the assessee was allowed, and the penalty of Rs. 14,42,682/- imposed under Section 271(1)(c) was directed to be deleted. en-us Fri, 31 Oct 2014 00:00:00 +0530 Thu, 17 Dec 2015 23:51:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=269656 The Tribunal concluded that the penalty under Section 271(1)(c) was not justified. The key reasons included that the amounts in question were opening balances from previous years, not taxable in the current year, the surrender of income was not voluntary, and the AO did not conduct an independent inquiry during penalty proceedings. Additionally, assessment and penalty proceedings are distinct, and the penalty cannot be imposed solely based on the assessment order's findings. The appeal of the assessee was allowed, and the penalty of Rs. 14,42,682/- imposed under Section 271(1)(c) was directed to be deleted. Case-Laws Income Tax Fri, 31 Oct 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=269656