2016 (9) TMI 1303

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..... lied on MAK Data vs. CIT(2013 (11) TMI 14 - SUPREME COURT) . In that case the survey was of the assessee’s sister concern. During its course several documents which had been undisclosed by that concern were found and recovered. During the course of assessment proceedings, when the assessee was questioned about those documents it offered to surrender substantial income on the basis of which penalty .....

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..... ection 260A is whether the ITAT fell into error in directing the division of the appellant s income included in the assessment? The assessee was subjected to survey under Section 133A during the course of which his statement was recorded. The tribunal relied upon the decision reported as CIT vs. S Khakder Khan reported as (2008) 300 ITR 157 (Madras) and CIT, Ranchi vs. Ravindra Kumar Ja .....

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..... y proceedings were drawn. The entire focus of discussion was on whether the penalty was correctly levied and the court held that it was. We are of the opinion that the rulings of this court relied upon by the tribunal in Ravindra Kumar Jain s case ( supra ) was appropriate. There is nothing to show any material supportive of the statement made in the course of survey proceedings was foun .....

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