https://www.taxtmi.com/caselaws?id=464759 ITAT held that penalty under s. 271(1)(c) could not be sustained where a revised return disclosing additional income after search was accepted in full by the AO without use of seized material to rebut it, and estimated additions were later reduced on appeal to profit-based figures. The Tribunal found no positive evidence of deliberate concealment and treated the post-search disclosure as bona fide for the facts, observing that procedural deeming to initiate penalty does not override substantive merits; penalty was deleted for the assessment years in question. en-us Mon, 03 Jun 2013 00:00:00 +0530 Thu, 13 Nov 2025 11:21:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=464759 ITAT held that penalty under s. 271(1)(c) could not be sustained where a revised return disclosing additional income after search was accepted in full by the AO without use of seized material to rebut it, and estimated additions were later reduced on appeal to profit-based figures. The Tribunal found no positive evidence of deliberate concealment and treated the post-search disclosure as bona fide for the facts, observing that procedural deeming to initiate penalty does not override substantive merits; penalty was deleted for the assessment years in question. Case-Laws Income Tax Mon, 03 Jun 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=464759