Section 271(1)(c) Penalty Imposed Despite No Incriminating Material; Taxpayer Voluntarily Declared Income and Paid Taxes.

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....Penalty u/s. 271(1)(c) - unexplained share application money and unsecured loans - No incriminating material was found during the curse of search relating to the alleged surrender of income made by the assessee in the Income Tax Return. The assessee suo moto offered the additional income in the return and paid taxes there on. It is also an established fact in the instant case that Ld. A.O. was not sure that which assessee has concealed the particulars of income or furnished inaccurate particulars of income. - AT....