2002 (8) TMI 251

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....ome and claimed benefit of Amnesty Scheme which was then brought into effect by circular issued by CBDT. The AO did not allow the benefit of Amnesty Scheme by holding that the filing of the revised return was after search conducted at the premises of M/s Shroff. The assessees have not filed the revised return suo motu, therefore, the ITO has imposed the penalty under ss. 271(1)(c) and 273(1)(b) for concealment of the income and not paid the advance taxes. 3. The CIT(A) has confirmed the order of the AO. Therefore, being aggrieved by this order, assessees are in appeal before us. 4. The learned counsel submitted that the assessees are as individuals and partners in the firm of M/s Patel Brothers. Smt. Chandrikaben and her husband Shara....

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....ign currency and the assessees with a view to get the mental peace declared the 50 per cent of the gift so received by their children as their income and filed the revised return under Amnesty Scheme as per Circular No. 451. The learned counsel further submitted that the assessees had voluntarily filed the revised return and made full disclosure of their income and full taxes thereon paid within the time-limit prescribed. The learned counsel submitted the return filed by the assessees were accepted in total and there was no variation in the income assessed by the ITO nor there was either any inquiry or findings adverse to the return filed so. The learned counsel has filed the copy of the judgment of CIT vs. Labhubhai Bhimjibhai Patel (IT Ap....