Penalty cannot be imposed for Bonafide omission during return filing, surfaced during Section 148/148 Assessment

Pankaj Kumar Gupta Vs. ITO (ITAT Lucknow) t the very outset, we observe that as appearing on record, in the return filed by the assessee the tax on sale of immovable property was not paid or entered into. However, when notice under section 148 of the Act was issued, assessee himself attended the proceedings and thereafter paid the entire tax on the same date when the assessment order was finalised. This element of behaviour on the part of the assessee shows that when he had filed the return, there was some omission on the part of the assessee to include the tax on the sale of property. However...