TMI Blog2014 (12) TMI 849X X X X Extracts X X X X X X X X Extracts X X X X ..... nd the date of revised computation, the surrender cannot be regarded as voluntary – there was no substance in the submission - the submission requires the Court to re-appreciate the factual material which is impermissible – as such no substantial question of law arises for consideration – Decided against revenue. - ITA No. - 244 of 2014 - - - Dated:- 24-11-2014 - Dr. Dhananjaya Yeshwant Chand ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e imposed a penalty. 2. The penalty was deleted in appeal by the Commissioner of Income Tax (Appeals)the CIT (A) inter alia on the ground that the assessee had filed a revised computation suo motu and voluntarily on 25 September 2003 and had deposited the tax and interest thereon. The CIT (A) held that the amount of ₹ 35 lacs was in the nature of an agreed addition and there was a lack of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Tax (Investigation), Kanpur; and, (3) Whether the Hon'ble Income Tax Appellate Tribunal was justified in not appreciating the fact that the assessee had failed to prove the identify, credit worthiness of the donor and also the genuineness of the transaction. 4. The Tribunal has confirmed the finding of fact which has been arrived at by the CIT (A). The only submission which was urge ..... X X X X Extracts X X X X X X X X Extracts X X X X
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