No section 271(1)(c) Penalty on Income Surrendered Voluntarily during Assessment

Aravind Kumar Agarwal Vs ACIT(OSD) (ITAT Kolkata) The issue under consideration is whether Penalty u/s 271(1)(c) can be levied in the case where the assessee surrendered the income voluntarily during the course of the assessment? ITAT states that the law that quantum and penalty proceedings stand on different footing and each and every disallowance/addition in the former does not ipso facto attract the latter penal provision. They keep in mind the very distinction and notice that the assessee has filed all the relevant supporting evidence in support of genuineness of this above-stated long-ter...