Disclosure of Additional Income in S. 153C Proceedings Does Not Automatically Prove Guilty of Concealment of Income: ITAT

The Income Tax Appellate Tribunal (ITAT) has provided clarity on the issue of concealment of income, ruling that the mere disclosure of additional income during survey proceedings does not automatically prove guilt. The case involved an assessee who, during a survey, offered additional income. The Assessing Officer subsequently initiated penalty proceedings for concealment. The ITAT, however, held that if the assessee voluntarily discloses the income and incorporates it into the return filed, a penalty for concealment cannot be automatically levied. The Tribunal emphasized that for a penalty to be imposed, the revenue must prove that the assessee deliberately concealed or furnished inaccurate particulars of income.