Indian Kanoon - Search engine for Indian Law

2.Whether the Tribunal is right in law in treating the revised return filed by the assessee as a valid return and holding that the same was filed to avoid confrontation with the Revenue and thereby coming to the conclusion that the additional income declared therein does not form a basis for levy of penalty u/s.271(1)(c) of the Income Tax Act, whereas, the original return filed by the assessee has no omission so as to treat the revised return as a valid one?

3.Whether on the facts and in the circumstances of the case and in law, the admission made by the assessee in the revised return offering higher amount of income does not attract penalty in view of Explanation 1 to Section 271(1)(c) of the Income Tax Act, 1961?