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Case Law Details

Case Name : Amandeep Singh Sran Vs DCIT (ITAT Delhi)
Appeal Number : ITA No. 4020/Del/2017
Date of Judgement/Order : 31/08/2023
Related Assessment Year : 2009-10
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Amandeep Singh Sran Vs DCIT (ITAT Delhi)

Introduction: The Income Tax Appellate Tribunal (ITAT) Delhi has upheld a penalty order against Amandeep Singh Sran under Section 271(1)(c) of the Income Tax Act for concealing income particulars. This article provides an overview of the case, details of the penalty proceedings, and the ITAT’s decision.

Detailed Analysis:

1. Background: Amandeep Singh Sran filed his original income tax return for Assessment Year (A.Y.) 2009-10, declaring a total taxable income of Rs. 21,12,940. Subsequently, a search and seizure operation under Section 132 of the Income Tax Act was conducted at his business and residential premises on November 20, 2009, as part of the HBN Group of cases. Following this, proceedings were initiated under Section 153A by issuing a notice on June 2, 2010.

2. Revised Return: In response to the notice, Amandeep Singh Sran filed a revised return of income on November 22, 2010, declaring the same total taxable income of Rs. 21,12,940. The assessment was eventually completed under Section 153A on December 28, 2011, with an increased taxable income of Rs. 5,21,12,940. This increase was attributed to income from undisclosed sources, resulting in an addition of Rs. 5,00,00,000.

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