2008 (4) TMI 839

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....s. Kavita Jha. ORDER 1. In these five appeals under section 260A of the Income-tax Act, 1961, pertaining to assessment years beginning from 1972-73 onwards, the following substantial question of law arises for consideration:-- Whether the Income-tax Appellate Tribunal was correct in law in deleting the undisclosed income of the assessee as recorded by the Securities and Exchange Com....

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....assessee has no desire to protract the litigation and some reasonable amount may be added by the income-tax authorities by spreading over the same in the relevant assessment years and taxed accordingly. It was also stated that penalty proceedings may not be launched against the assessee. 3. Based on the information received from USA and the admissions made by the assessee, the Assessing Officer....

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....repared to surrender the amount since it does not want any protracted litigation and prayed that penalty proceedings may not be launched against the assessee. 6. In view of the facts which have emerged from the complaint made by the SEC in USA as well as the letters sent by the assessee to the Income-tax Department in India, there can be no manner of doubt that the assessee had certain amounts ....