2019 (4) TMI 1600

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....me for the year under consideration was filed by it on 17.09.2011 declaring a total income of Rs. 4,44,860/-. During the course of assessment proceedings, two balance sheets and trading and profit and loss accounts were submitted by the assessee, one for the period from 01.04.2010 to 31.05.2010 and the other for the period from 01.06.2010 to 31.03.2011. A consolidated computation of total income for the said two periods was also submitted by the assessee showing a total income for the previous year relevant to A.Y. 2011-12 at Rs. 7,96,343/-. Since the total income of the assessee as declared in the return of income was only Rs. 4,44,816/-, the AO required the assessee to explain the difference. In reply, it was submitted on behalf of the as....

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....d that the assessee firm itself however prepared and furnished a consolidated computation of total income prepared on the basis of consolidated profit and loss account and offered the additional income voluntarily to tax. He contended that the Assessing Officer on the basis of these consolidated statements prepared and furnished by the assessee raised the issue of difference in the income returned and there being no case of detection by the AO of such income, addition made to the total income of the assessee on the basis of assessee's own working furnished during the assessment proceedings cannot be treaed as its concealed income to attract the penalty u/s 271(1)(c) of the Act. 5. The learned DR, on the other hand, submitted that the asses....