Larger Bench of High Court deciding a bunch of Appeals vide a significant ruling has ruled that power to impose penalty under Section 271 of the Act depends upon the satisfaction of the Income Tax Officer in the course of the proceedings under the
There was a general investigation by the Investigation wing regarding a fake gift racket. There was no information with the AO when the assessee voluntarily surrendered the income, that gifts or credits received by assessee were fake. In the assessme