No penalty on income suo motu offered by assessee in his return of income

ACIT Vs Swapnadeep Krushi Paryatan Kendra (ITAT Pune) The AO has imposed penalty only with reference to the amount of Rs.1.50 crore which was suo motu declared by the assessee in the return. In that view of the matter, the ratio laid down in MAK data Pvt. Ltd. (supra) has no application to the facts of the extant case as the income under consideration, forming the foundation for the penalty, is not the one which was added by the AO beyond the income returned. In view of the fact that the assessee voluntarily offered the income, declared in the survey, in the return of income and the assessment...