https://www.taxtmi.com/caselaws?id=787611 Where amounts admitted during a survey were recorded in books, declared in the return filed within time and treated as business income in a regular assessment under Section 143(3), penalty under Section 271(1)(c) cannot be imposed absent proof of concealment or furnishing of inaccurate particulars; penal provisions require strict construction and cannot rest on presumption or conjecture. The analysis concludes that surrender followed by timely disclosure and acceptance in assessment negates exigibility of penalty, and the Revenue's appeal against deletion of the penalty fails in favor of the assessee. en-us Wed, 07 Jan 2026 00:00:00 +0530 Tue, 10 Mar 2026 08:51:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=787611 Where amounts admitted during a survey were recorded in books, declared in the return filed within time and treated as business income in a regular assessment under Section 143(3), penalty under Section 271(1)(c) cannot be imposed absent proof of concealment or furnishing of inaccurate particulars; penal provisions require strict construction and cannot rest on presumption or conjecture. The analysis concludes that surrender followed by timely disclosure and acceptance in assessment negates exigibility of penalty, and the Revenue's appeal against deletion of the penalty fails in favor of the assessee. Case-Laws Income Tax Wed, 07 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787611