Penalty Sustained Because Tax Paid Without Return Doesn’t Disclose Income Details

Vitthalbhai Ashabhai Patel Vs ITO (ITAT Ahmedabad) No Return u/s 139 & Return Filed Long After Sec.148 Deadline — Explanation 3 to Sec.271(1)(c) Automatically Deems Concealment; Penalty of ₹18.55 Lakh Upheld In this appeal, Vitthalbhai Ashabhai Patel challenged the penalty of ₹18,55,865/- levied u/s 271(1)(c) for AY 2011-12. The Assessee had sold an immovable property for ₹98,50,000/- on 04.03.2011 but did not file the return u/s 139. Based on information received, the Department issued notice u/s 148 on 28.03.2018. Interestingly, the Assessee deposited ₹17,76,143/- as tax on 27....