Mere voluntary disclosure does not release assessee from penalty

Tribunal upheld the imposition of penalty under Section 271(1)(c) of the Act. This by negativing the assessee’s contention before it that allocating/ debiting the foreign exchange loss to determine its non­tonnage income, was a mistake and the mistake had been voluntarily disclosed by the appellant during the assessment proceedings. The contention of the appellant was not accepted as the so-called disclosure was made by the appellant only after it received notices under Section 142(1) & 143(2) of the Act, calling for various details. Moreover, the Explanation offered by the appellant fo...