2024 (12) TMI 393 - SCH - Income Tax

Penalty u/s 271AAA(1) - assessee declared the surrendered amount under the head additional income which was accepted by the Revenue - purported failure on the part of the assessee to substantiate the manner in which the undisclosed income was derived - as decided by HC 2024 (7) TMI 1561 - DELHI HIGH COURT it cannot be said that the assessee has fulfilled the requirement that she, in her statement (under section 132(4)) substantiates the manner in which the undisclosed income was derived . Such being the case, this court is of the opinion that the lower appellate authorities misdirected themselves in holding that the conditions in section 271AAA(2) were satisfied by the assessee. HELD THAT - We concur with the view taken by the Delhi High Court about the interpretation of sub-section 2 of Section 271AAA of the Income Tax Act, 1961. Hence, no case for interference is made out in exercise of our jurisdiction under Article 136 of the Constitution of India. The Special Leave Petition is accordingly dismissed.

Summary

The Supreme Court dismissed the Special Leave Petition, concurring with the Delhi High Court's interpretation of sub-section 2 of Section 271-AAA of the Income Tax Act, 1961. Delay was condoned, and no interference was found necessary under Article 136 of the Constitution of India.