Penalty U/s. 271(1)(c) leviable on Income disclosed in return filed pursuant to notice U/s. 153A without proper explanation

The assessee having returned the additional income of Rs. 153.99 lakhs in pursuance to notice under section 153A, which it admits as having done voluntarily, how, we wonder, is it not a case squarely governed by the said Explanation 5A. The assessee in fact admits to the sum credited to the account “advance from allottees” as representing its income. The same, it needs to be appreciated, does not explain, much less satisfactorily, the nature and source of the said credit, so that section 68, deeming the same as the assessee’s income for the current year, s

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