2014 (12) TMI 849

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..... of the Income Tax Act, 1961 the Act of Rs. 12,28,500/-. The penalty was imposed on the ground that the assessee had initially received a sum of Rs. 35 lacs as a gift. During the course of the assessment proceedings, the assessee was asked to furnish the details of the gift. In the meantime, the Directorate of Income Tax (Investigation), Kanpur commenced enquiries. On 25 September 2003 the assesse .....

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..... following questions of law:         "(1) Whether the ITAT erred in law in interpreting the phrase "concealed particulars of income or furnished inaccurate particulars" as contained in Section 271(1)(c) when both these conditions are fulfilled in the present case;     (2) Whether the Hon'ble Income Tax Appellate Tribunal was justified in hold .....

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..... f original assessment and the date of revised computation, the surrender cannot be regarded as voluntary. We find no substance in the submission. Essentially, the submission requires the Court to re-appreciate the factual material which is impermissible. 5. Hence, no substantial question of law is raised. The appeal is, accordingly, dismissed. There shall be no order as to costs.
Case laws, D .....

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