Penalty cannot be imposed in respect of income surrendered without linking to incriminating documents

Relevant Extract of the Judgment 3. The relevant facts are that a search & seizure operation was conducted at the premises of the assessee and its group company on 18.02.2011. In response to the notice issued under sec. 153A, the assessee furnished return of income along with year-wise bifurcation of Rs.10 crores surrendered by the assessee immediately after the completion of search. The Assessing Officer framed assessments under 153A accepting the returns of income filed for the assessment years under consideration. The Assessing Officer thereafter initiated penalty proceedings under sec....