Validity of summon order passed by trial court and criminal proceedings u/s 279(1) r.w. section 276D

Brief Background of case The petitioner by letter dated 17th November, 2011 had disclosed a foreign bank account which existed with the HSBC Private Bank, Geneva, Switzerland to the Director of Income Tax (Investigation-II). The peak amount lying in the said account during the year ending 31st March, 2007 was around US$ 1.3 million. The account was closed in the year 2007. After recording the petitioner’s statement on 24th November 2011 and 9th December 2011 u/s 131 of the I.T. Act, DCIT issued notice dated 9th July 2012 u/s 148 of the Act. In response, return of income declaring the peak ba...