Revised return filed before assessment cannot mean concealment- ITAT Jaipur deletes penalty u/s 271(1)(c) -Vague notice & voluntary disclosure save assessee from penalty

Kanhaiyalal Rameshwar Das Vs ACIT (ITAT Jaipur) Both appeals by the Assessee, a partnership firm of the Bundi Silica Group, Kota engaged in sandstone mining, challenged confirmation of penalties of ₹ 4.04 lakh (A.Y. 2012-13) & ₹ 2.79 lakh (A.Y. 2014-15) levied u/s 271(1)(c). A search u/s 132 was conducted on 05-02-2015 in the group. Pursuant to notice u/s 153A, the Assessee filed return on 08-06-2015 declaring income of ₹ 92.85 lakh. Later, to rectify an omission of ₹ 13.09 lakh (undisclosed investment in plot surrendered during search), it voluntarily filed a revised return on 19-...