Disclosure of Income after Search at sister concerns office cannot be called voluntary

Brief of the case:

High Court Calcutta held in CIT Vs Balampur Chini Mills Pvt Ltd that even if the assesse had voluntary disclosed its income by filing revised ROI though not detected by the revenue during scrutiny proceedings u/s 143(3), penalty u/s 271(1)(c) would be levied.  Moreover High Court held that it was a presumption of sec 271(1)(c) that when there was difference between the assessed income and income returned by the assesse then penalty u/s 271(1)(c) would be levied. Moreover if search wo

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