Penalty u/s 271(1)(c) Not Leviable Where Survey Disclosure Is Declared in Return & Accepted

ACIT Vs Radhika Jewellers (ITAT Ahmedabad)

Income Tax Appellate Tribunal, Ahmedabad upheld the order of the CIT(A) deleting the penalty of ₹62.11 lakhs levied under Section 271(1)(c) on income disclosed during survey proceedings. The Tribunal noted that during a survey under Section 133A, the assessee-firm admitted unaccounted stock and cash aggregating to about ₹2.01 crores, which was duly recorded in the books and declared as business income in the return filed within the prescribed time. The Assessing Officer accepted the returned income in assessment under Section 143(3), m

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