Court Upholds Penalty u/s 271(1)(c) Due to Non-Voluntary Income Disclosure During Tax Survey Proceedings.

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....Penalty u/s. 271(1)(c) - surrender of income in survey proceedings - From the conduct of the assessee, it is clear that the surrender was lacking voluntariness. In our view the assessee was forced to disclose the income on account of survey and subsequent show cause notice issued by the assessing officer. In view of the above said we do not find any justification for the CIT(appeals) to delete the penalty - AT....