Penalty leviable if Assessee not Discloses source of Income despite voluntary disclosure

Principal CIT Vs. Smt. Ritu Singal (Delhi High Court)

In construing Section 271AAA one must not lose sight of its essential purpose which resulted in its enactment. There is a penalty at the rate of 10% of the undisclosed amount declared, if the conditions in Section 271AAA (2) are not met with. This is quite different from the penal provision under Section 271 (1) (c) of the Act, which directs that if income is concealed or inaccurate returns are filed, which are disallowed by the AO, the penalty shall be ―three times the amount

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