9911796707
TMI Blog2021 (3) TMI 457X X X X Extracts X X X X X X X X Extracts X X X X ..... he aforesaid appeal has been filed by the assessee against the impugned order dated 14/03/2018, passed by the CIT(A)- 56, Mumbai, for the assessment year 2009-10. 2. The only effective issue raised by the assessee in the various grounds of appeal is against the confirmation of penalty of Rs. 2,36,914/- by CIT(A) as imposed by the AO u/s.271(1)(C) of the Act. 3. The facts in brief are that the as ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tion of Rs. 67,23,000/- for which there was another agreement dated 08/04/2008 for consideration of Rs. 33,00,000/- only from the same vendors meaning thereby that the difference of Rs. 34,23,000/- was paid in cash by M/s. Gold Finch Jewellers Ltd., to the assessee and another co-owners. Consequently , the case of the assessee was re-opened by u/s.147 of the Act by issuing notice under section 148 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of the assessee to furnish the income fully and truly in the return of income. The AO imposed penalty equal to 100% of the tax to be evaded which worked out to Rs. 2,36,914/- for concealment of income by invoking Explanation 1 to Section 271(1)(c) of the Act. 4. In the appellate proceedings, the ld. CIT(A) affirmed the order of the AO by holding that assessee has furnished inaccurate particulars ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ade was Rs. 32,500 which was equal of 25% of the cost of improvement. In this case we note that no notice was issued u/s.148 prior to the filing of the revised return and thus, we note that assessee has voluntarily suo-motto filed the revised return of income and offered to tax whatever was left from being disclosed in the original return of income. In other words, the revised return was not filed ..... X X X X Extracts X X X X X X X X Extracts X X X X
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