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9. Mr. Chhotatray relied on Mak Data P.Ltd. Vs. Commissioner of 5 of 6 1252-ITXA-1424-2017.doc Income Tax-(II) reported in Indian Kanoon-http://indiankanoon.org/ doc/149438153 to submit that just because the assessee voluntarily disclosed his income, it can not be said that there was no concealment. Facts in the case at hand, are different in as much as in Mak Data Pvt. Ltd. (supra), the Apex Court came to conclusion that the surrender in that case was not voluntary. In the case at hand, the Tribunal has correctly come to a conclusion that the declaration was voluntary.