Section 133, 271 of Income tax Act, 1961—penalty u/s 271(1)(c)— In the instant case, survey under section 133A was carried out at the premises of the assessee on 28.3.2012 i.e. much prior to the closing dates of accounts and date of filing of return under section 139(1) of the Act. The assessees have admitted an amount of 70 lakhs and 22.45 crores respectively during the survey action which were subsequently shown in the regular returns of income filed under section 139(1) of the Act.
However penalty u/s 271(1)(c) was levied on the premise that the assessee would not have disclosed the receipt of on-money, but for the survey action.

Held that— There are number of judgments available on this issue where it is held that when an assessee has made a complete disclosure in the return of income and offered the admitted amount for taxation, then there is no question of concealment of income or furnishing inaccurate particulars of income so as to attract provisions of section 271(1)(c) of the Act.[DCIT, CENT. CIR. 2 (2) AHMEDABAD. VERSUS MANN CORPORATION MALA HILLS, YAMUNAJI CORPORATION] [2019] 12 ITCD Online (28) [ITAT AHMEDABAD]