https://www.taxtmi.com/caselaws?id=781339 ITAT JAIPUR - AT held that penalty under s.271(1)(c) cannot be imposed where additional income disclosed during survey was subsequently offered in the return filed under s.139(1) and again under s.153A and accepted by the AO. Section 271(1)(c) must be strictly construed and concealment is to be assessed by reference to particulars in the return; a loose paper disclosure during survey, without corroborative evidence of concealment, is insufficient to sustain penalty. Accordingly, the penalty was deleted. en-us Wed, 24 Sep 2025 00:00:00 +0530 Fri, 14 Nov 2025 09:42:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=781339 ITAT JAIPUR - AT held that penalty under s.271(1)(c) cannot be imposed where additional income disclosed during survey was subsequently offered in the return filed under s.139(1) and again under s.153A and accepted by the AO. Section 271(1)(c) must be strictly construed and concealment is to be assessed by reference to particulars in the return; a loose paper disclosure during survey, without corroborative evidence of concealment, is insufficient to sustain penalty. Accordingly, the penalty was deleted. Case-Laws Income Tax Wed, 24 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=781339