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TMI Blog2019 (5) TMI 1384X X X X Extracts X X X X X X X X Extracts X X X X ..... Moreover, the assessee had no valid reason for concealment and furnishing of inaccurate particulars in the belated return filed against the notice u/s 153A . In the absence, of any valid reason for not filing the return of income within the time stipulated u/s 139 or declaring complete particulars of income in the belated return filed by the assessee, the penalty levied u/s 271(1)(c) was sustained by the Tribunal. While adjudicating the appeal, the Tribunal has considered all the grounds relating the effective ground raised by the assessee. In view of the above, we find no merit in the miscellaneous petition filed by the assessee. - M.P. No. 78/Chny/2017 [In I.T.A. No.1112/Chny/2015] - - - Dated:- 21-5-2019 - Shri A. Mohan ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t. Only after conduct of search operation under section 132 of the Act and after issuing notice under section 153A of the Act, the assessee has come forward to file his belated return of income. After scrutiny of seized materials and verification of particulars filed by the assessee, the Assessing Officer found that the assessee has made undisclosed investments. During the course of penalty proceedings, the assessee has simply stated that out of the three additions made, the assessee has agreed for the addition made on unexplained investment to the tune of ₹.60 lakhs to have amicably settled with the Department. The assessee did not have any credible and cogent explanation for not offering the income in the form of unexplained investm ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... redible and cogent explanation for not offering the income in the form of unexplained investment in property pertaining to previous years ending before the search and such unexplained investment came into light only during the course of search operation and thus, tantamount to concealment of particulars of income within the meaning of Explanation 5 to section 271(1)(c) of the Act. Moreover, the assessee had no valid reason for concealment and furnishing of inaccurate particulars in the belated return filed against the notice under section 153A of the Act. In the absence, of any valid reason for not filing the return of income within the time stipulated under section 139 of the Act or declaring complete particulars of income i ..... X X X X Extracts X X X X X X X X Extracts X X X X
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