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High Court in the case of Grass Field Farms Resorts Pvt. Ltd. vs. DCIT, 388 ITR 395 (Raj.) and submitted that the disclosure made by the assessee in the revised return only because of the material and documents found during the survey and statement was recorded. Therefore, the same cannot be held as voluntary. The ld. D/R has also relied upon the decision of Hon'ble Supreme Court in the case of Mak Data Pvt. Ltd. vs. CIT, 358 ITR 593 (SC) and submitted that Hon'ble Supreme Court has held that surrender of income is not voluntary in the sense that the offer of surrender was made in view detection made by the AO in the search conducted in the sister concern of the assessee. Thus the ld. D/R has submitted that it is clearly a case of concealment of income and the assessee disclosed the said income of Rs. 46,00,000/- only because of survey action taken by the AO. He has relied upon the order of the A.O. 3.1. As regards the other addition on which the penalty was deleted or reduced by the ld. CIT (A), the ld. D/R has relied upon the order of the AO. 3.2. On the other hand, the ld. A/R of the assessee has submitted that the return of income was filed within the period of limitation permissible under section 139 of the Act and, therefore, the same cannot be considered as undisclosed income of the assessee when there is no addition made by the AO in the return of income. When a valid revised return of income was filed and accepted by the AO then the amount offered to tax in the return of income cannot be held as concealed income. Further, the ld. A/R has submitted that even otherwise this was not a real income of the assessee but only advances were received by the assessee without any actual sale during the year under consideration. The income would arise or accrued only at the time of sale in the subsequent year. Hence the mere surrender of income by the M/s. Gajanan Towers Pvt. Ltd.