Penalty for concealment of Income not leviable for Voluntary disclosure without detection by dept.

Penalty for concealment of Income can not leviable for Voluntary disclosure of Income after receipt of questionnaire in the absence of any detection or information in possession of the Revenue- 

CIT Vs. Harnarai (Delhi High Court)- Word ‘concealment’ requires there to be a deliberate act on the part of the assessee, and the concealment inherently carries with it the element of mens rea. It was further observed that a mere omission from return of any item of receipt does neither am

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