#Voluntary Disclosure

ITAT Pune rules that penalty under Section 270A of the Income Tax Act cannot be imposed if the assessee voluntarily discloses additional income through a return filed under Section 139(8A) before issuance of a Section 148 notice. This holding reinforces the principle that voluntary compliance prior to reassessment notice precludes penalty, offering critical protection to taxpayers.

The ITAT Pune has ruled that penalty under Section 271(1)(c) cannot be imposed when an assessee voluntarily discloses undisclosed income in response to a notice under Section 153A, provided no incriminating material was found during the search. This affirms that disclosure in compliance with statutory procedure negates the presumption of concealment, offering critical relief to taxpayers who cooperate post-search.