Penalty U/s. 271(1)(c) justified on income disclosed during survey

Kashish Enterprise Vs ITO (ITAT Rajkot) It is a fact on record, the assessee did not disclose the income voluntarily but it was disclosed in pursuance to the survey conducted u/s 133A of the Act. During the course of survey, certain documents were found and seized which were sufficient enough to make the addition in the hands of the assessee. Therefore the assessee has disclosed income of Rs. 53,09,666/-. Thus, in our considered view had there not been survey u/s 133A of the Act, the assessee would not have offered such undisclosed income. Therefore, in our considered view, the penalty u/s 271...