Offering lower amount than income surrendered during course of search

Daya Properties and Finance Vs ACIT (ITAT Indore) We observe that during the course of search cash sum of Rs.37,02,020/- was found and assessee failed to explain its source and accepted to offer it as additional income. No specific retraction was made before filing of return of income. In the return of income assessee partly honoured the surrender by offering Rs.22,00,000/- as undisclosed income as against Rs.37,02,020/- made during the course of search. It is true that the assessee had not made any specific retraction showing its intention to not to offer Rs.15,02,020/- to tax. However before...