If section 147 proceedings initiated after Income deceleration by Assessee than conclusion of non- voluntary return is untenable

Ravina & Associates Pvt. Ltd. Vs Addl. (ITAT Delhi) 1. The undisputed facts are that in the original return of income filed by the assessee for the instant years, the income representing the deposits in the bank account with Natwest Bank, London was not declared by the assessee. It is also undisputed that the said income was subsequently declared in the returns of income furnished during the re­assessment proceedings and also assessed in the impugned orders of assessment. There is no dispute as to taxability of income. The claim of the assessee is that the said income was duly disclosed v...