Case Law Details
Pr. CIT Vs Ritu Singal (Delhi High Court)
The assessee merely stated that the sums advanced were undisclosed income. However, she did not specify how she derived that income and what head it fell in (rent, capital gain, professional or business income out of money lending, source of the money etc). Unless such facts are mentioned with some specificity, it cannot be said that the assessee has fulfilled the requirement that she, in her statement (under Section 132 (4)) ―substantiates the manner in which the undisclosed income was derived‖. Such being the case, this court is of opinion that the lower appellate authorities misdirected themselves in holding that the conditions in Section 271AAA (2) were satisfied by the assessee.
FULL TEXT OF THE HIGH COURT ORDER / JUDGMENT
1. The question of law in the present appeal by the revenue, framed in this case reads as follows:
” Did the ITAT fall into error in deleting the penalty under Section 271AAA of ` 20,000,000/- added pursuant to search in the overall circumstances of the case?‖
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