Income disclosure under fear of penalty or other proceedings cannot be termed voluntary

Dy. CIT Vs. Mukesh Kalubhai Prajapati (ITAT Ahemdabad)

We observe that the additions have been made under s.68 of the Act as purported lender M/s.Sudarshan Enterprise denied having been lent the money to the assessee. As a consequence of the revelations on inquiry, the assessee grudgingly came forward for admission of the aforesaid loan as unexplained income. Thus, plea of the assessee that the disclosure was made voluntarily or in good faith is difficult to appreciate. A disclosure made under the fear

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