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“Section 142(1)”

Section References (mined)Section 142Section 142(1)15,051 judgments

The decision most relied on for Section 142(1) is Collector, Land Acquisition v. Mst. Katiji (167 ITR 471), cited in 3,926 judgments on BharatTax.

Leading authorities on Section 142(1)

Collector, Land Acquisition v. Mst. Katiji
167 ITR 471 · 1987 · Supreme Court
3,926
citing judgments

Delay in filing appeals, when supported by sufficient or justifiable cause, should be condoned with a liberal approach to ensure substantial justice. This principle prioritizes the cause of justice over mere technicalities.

Malabar Industrial Co. Ltd. v. CIT
243 ITR 83 · 2000 · Supreme Court
2,943
citing judgments

For revision under Section 263, the Assessing Officer's order must be both erroneous and prejudicial to the interests of the revenue; if either condition is not met, the revisionary jurisdiction cannot be invoked. An order is not erroneous merely because the Assessing Officer did not record the details of enquiries conducted, provided due enquiries were made.

CIT v. Multiplan India Ltd.
38 ITD 320 · 1991 · ITAT
2,267
citing judgments

An appeal before the Income Tax Appellate Tribunal can be dismissed for non-prosecution or treated as unadmitted when the appellant fails to appear, cooperate, or show diligence, in accordance with Rule 19(2) of the Income-tax (Appellate Tribunal) Rules. The law aids the vigilant, not those who sleep on their rights.

Estate of Late Tukojirao Holkar v. CWT
223 ITR 480 · 1997 · High Court
2,040
citing judgments

A court or tribunal is not bound to answer a reference or adjudicate an appeal on its merits if the party at whose instance the proceeding is made fails to appear at the hearing or take necessary steps for its proper conduct.

Sumati Dayal v. CIT
214 ITR 801 · 1995 · Supreme Court
1,967
citing judgments

The Revenue is entitled to look behind the apparent form of a transaction to discover its true nature, applying the test of human probabilities and surrounding circumstances. If transactions defy logic or are unnatural, they can be treated as bogus, even if supported by some documentation, especially in cases of cash credits or unexplained investments.

CIT v. Kelvinator of India Ltd.
320 ITR 561 · 2010 · Supreme Court
1,673
citing judgments

An Assessing Officer cannot initiate reassessment proceedings under Section 147 of the Income Tax Act based on a mere change of opinion. Reassessment is permissible only when there is fresh tangible material leading to the belief of income escapement, not merely a review of existing facts.

CIT v. B.N. Bhattacharya & Another
118 ITR 461 · 1997 · Supreme Court
1,656
citing judgments

Appealing a tax assessment requires more than just filing the appeal; it involves actively pursuing it. The assessee must effectively engage with the appellate process.

CIT v. Durga Prasad More
82 ITR 540 · 1971 · Supreme Court
1,579
citing judgments

Tax authorities must judge evidence using the test of human probabilities and consider the apparent as real until there are reasons to believe it is not. They can rely on circumstantial evidence and the preponderance of probabilities to determine the genuineness of transactions.

Judgments citing Section 142(1)

Barigala Saroja, Guntur vs. Income Tax Officer, Ward-2(1), Guntur

In the result, appeal filed by the assessee is allowed for statistical purposes as indicated herein above

ITA 472/VIZ/2024[2017-18]Status: DisposedITAT Visakhapatnam18 Jul 2025AY 2017-18

Bench: the Tribunal. In respect of the belated filing of the appeal, the assessee filed a petition seeking condonation of delay along with an affidavit dated 24/01/2025 and explained the reasons for such delay. For the sake of immediate reference, the contents of the said affidavit are extracted herein below: "1.......

Section 133(6)Section 139(4)Section 142(1)Section 144Section 69A

IN THE INCOME TAX APPELLATE TRIBUNAL VISAKHAPATNAM BENCH, VISAKHAPATNAM श्री रवीश सूद, माननीय न्याययक सदस्य एवं श्री एस बालाकृष्णन, माननीय

Sachin Dwivedi, Hardoi vs. ACIT, National Faceless Appellate Centre

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 762/LKW/2024[2018-19]Status: DisposedITAT Lucknow18 Jul 2025AY 2018-19

Bench: SH. SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: NoneFor Respondent: Sh. Amit Kumar, DR
Section 115BSection 142(1)Section 250Section 68

furnish details / documents in support of the return and for furnishing information / evidences as per the terms of the notices issued under section 142(1). However, ld. AO records that the assessee did not file details of contract receipt, details of direct and indirect expenses with documentary evidences or details

Lalji Yadav, Lucknow vs. ITO-1(2), Lucknow

In the result, the appeal of the assessee is allowed

ITA 729/LKW/2024[2017-18]Status: DisposedITAT Lucknow18 Jul 2025AY 2017-18

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharya.Y. 2017-18 Lalji Yadav, Vs. Ito-1(2), 3/152A, Vivek Khand, Gomti Lucknow (New) Nagar, Lucknow, U.P.-226010 Pan:Aakpy2220J (Appellant) (Respondent) Assessee By: Sh. P.K. Kapoor, C.A. Revenue By: Sh. Amit Kumar, Dr Date Of Hearing: 06.05.2025 Date Of Pronouncement: 18.07.2025 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed By The Assessee Against The Orders Of The Ld. Cit(A), Nfac Under Section 250 Of The Income Tax Act, 1961 Confirming The Penalty Levied Under Section 272A(1)(D) Levied By The Ito, Ward-9(1)(1), Lucknow Dated 27.01.2022. The Grounds Of Appeal Are As Under:- “1. Because The Assessment Order Dated 10.12.2019 Passed U/S 144 Of The Income Tax Act, 1961, Giving Rise To The Penalty Proceedings U/S 272A(1)(D) Of The Act, Has Been Set Aside By The Hon'Ble Income Tax Appellate Tribunal, Lucknow Bench 'A' Vide Order Dated 13.11.2024 Passed In Ita No. 448/Lkw/2024, Restoring The Matter To The Assessing Officer For Passing The Assessment Order Afresh, The Impugned Order Dated 09.10.2024 Passed By Ld. "Cit(A)" As Well As Penalty Order U/S 272A(1)(D) Do Not Survive & Consequently The Order Passed By The Lower Authorities Deserve To Be Set Aside. 2. Because The Order Appealed Against Is Contrary To Facts, Law & Principles Of Natural Justice. 3. The Appellant Craves Leave To Add, Delete Or Modify Any Of The Grounds Before Or At The Time Of Hearing Of Appeal.”

For Appellant: Sh. P.K. Kapoor, C.AFor Respondent: Sh. Amit Kumar, DR
Section 139(1)Section 142(1)Section 144Section 250Section 272A(1)(d)Section 69A

during the F.Y. 2016-17 and not filed his ITR for the assessment year 2017-18. Therefore, he issued a notice under section 142(1) requiring the assessee to file his ITR for the A.Y. 2017-18 by 30.12.2017. The ld. AO records, that despite the time limit given ... statutory notice under section 142(1), no ITR was filed by the assessee. Therefore, the assessment of the assessee was taken up for disposal under section 144 of the Income Tax Act. The ld. AO issued notices under section 142(1) and called information relevant for the completion of assessment

Shivashish Foundation Trust, Ahmedabad vs. The Jt.CIT(OSD), Circle-1 (Exemption), Ahmedabad

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 1003/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad18 Jul 2025AY 2017-18

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble**

For Appellant: Shri Kushal Fofaria, ARFor Respondent: Shri RP Rastogi, CIT(DR)
Section 11Section 11(1)(a)Section 11(2)Section 12ASection 13(1)(c)Section 142(1)Section 143(3)Section 234ASection 270ASection 80G(5)

CASS and notices under sections 143(2) and 142(1) of the Act were issued from time to time, including revised notices under section 142(1) r.w.s. 129 due to change in the incumbent officer. Thereafter, the Assessing Officer passed the order under section

Imrankhan Bismilakhan Malik, Ahmedabad vs. The ITO, Ward-3(3)(1), Ahmedabad

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 2126/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad18 Jul 2025AY 2017-18

Bench: Dr. B.R.R. Kumar, Vice-Ms Suchitra Kamble

For Appellant: Shri P F Jain, ARFor Respondent: Shri Kamal Deep Singh, Sr DR
Section 115BSection 142(1)Section 143(2)Section 144Section 234ASection 69A

examine credit card payments. Accordingly, a notice under section 143(2) of the Act was issued on 21.08.2018, followed by a notice under section 142(1) dated 10.10.2019 and a show cause notice on 19.11.2019. As there was no compliance from the assessee, the Assessing Officer completed the assessment

Shah Rakesh Bhikhabhai (HUF), Ahmedabad vs. The PCIT, Ahmedabad-1, Ahmedabad

In the result, the appeal filed by the assessee stands dismissed

ITA 415/AHD/2023[2018-19]Status: DisposedITAT Ahmedabad18 Jul 2025AY 2018-19

Bench: Shri T.R Senthil Kumar & Shri Narendra Prasad Sinha

For Appellant: Shri Vivek Chavda, ARFor Respondent: Shri A P Singh, CIT. DR
Section 142(1)Section 143(3)Section 80G

PCIT and other material brought on record. First, we should examine the fact whether assessing officer has conducted enquiry by issuing notice under section 142 (1) of the Income Tax Act 1961. in respect of the donation given by Rakesh Bhikhabhai(HUF) vs. PCIT Asst.Year –2018-19 - 12– the assessee ... tune of Rs. 30,00,000/-to Rashtriya Samajwadi party (Secular). The relevant para of the notice issued by the assessing officer under section 142(1) of the Income Tax Act 1961, is reproduced below: "You have furnished the detail/documents in response to the notice u/s 142(1

Shubham Trading Company, Nizamabad vs. ITO., Ward 1, Nizamabad

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 840/HYD/2025[2012-13]Status: DisposedITAT Hyderabad18 Jul 2025AY 2012-13

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri P. Murali Mohan Rao, C.AFor Respondent: Shri G. Saratha, SR-DR
Section 133(6)Section 143(3)Section 147Section 148Section 43B

आयकर अपीलीय अधिकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘B’ Bench, Hyderabad श्री विजय पाल राि, उपाध्

Star Organic Foods Inc, Nellore vs. ACIT., Circle-1, Nellore

In the result, appeal of the assessee is dismissed

ITA 715/HYD/2025[2018-19]Status: DisposedITAT Hyderabad18 Jul 2025AY 2018-19

Bench: Shri Manjunatha G & Shri Ravish Sood

For Appellant: CA, T Ram PrasadFor Respondent: Shri Gurpreet Singh, Sr. AR
Section 142(1)Section 143(2)Section 143(3)Section 5Section 69A

case has been taken-up for complete scrutiny under CASS. Notice under section 143(2) dated 28.09.2019 and subsequent notice under section 142(1) of the Act on various dates has been issued and served on the assessee. In response, the assessee has filed submissions from time to time

Geethala Tejaswini, Hyderabad vs. Income Tax Officer, Ward-15(1), Hyderabad

Appeals of the assessee are allowed for statistical purposes in terms of our aforesaid observations

ITA 325/HYD/2025[2014-15]Status: DisposedITAT Hyderabad18 Jul 2025AY 2014-15

Bench: Us:

Section 142(1)Section 144Section 147Section 148Section 271(1)(c)Section 68

return of income in compliance to notice under Section 148 of the Act, dated 30.03.2024 nor complied with the notices issued under Section 142(1) of the Act, therefore, the A.O., after validly putting the Geethala Tejaswini, Hyderabad. assessee to notice, proceeded with to frame the assessment to the best ... under Section 148 of the Act. Also, it was observed by him that the assessee, despite multiple statutory notices under Section 142(1) of the Act, served electronically and physically, had failed to come forth with any explanation regarding the deposits made in her bank account during the subject year

Geethala Tejaswini, Hyderabad vs. Income Tax Officer, Ward-15(1), Hyderabad

Appeals of the assessee are allowed for statistical purposes in terms of our aforesaid observations

ITA 324/HYD/2025[2014-15]Status: DisposedITAT Hyderabad18 Jul 2025AY 2014-15

Bench: Us:

Section 142(1)Section 144Section 147Section 148Section 271(1)(c)Section 68

return of income in compliance to notice under Section 148 of the Act, dated 30.03.2024 nor complied with the notices issued under Section 142(1) of the Act, therefore, the A.O., after validly putting the Geethala Tejaswini, Hyderabad. assessee to notice, proceeded with to frame the assessment to the best ... under Section 148 of the Act. Also, it was observed by him that the assessee, despite multiple statutory notices under Section 142(1) of the Act, served electronically and physically, had failed to come forth with any explanation regarding the deposits made in her bank account during the subject year

Geethala Tejaswini, Hyderabad vs. Income Tax Officer, Ward-15(1), Hyderabad

Appeals of the assessee are allowed for statistical purposes in terms of our aforesaid observations

ITA 323/HYD/2025[2013-14]Status: DisposedITAT Hyderabad18 Jul 2025AY 2013-14

Bench: Us:

Section 142(1)Section 144Section 147Section 148Section 271(1)(c)Section 68

return of income in compliance to notice under Section 148 of the Act, dated 30.03.2024 nor complied with the notices issued under Section 142(1) of the Act, therefore, the A.O., after validly putting the Geethala Tejaswini, Hyderabad. assessee to notice, proceeded with to frame the assessment to the best ... under Section 148 of the Act. Also, it was observed by him that the assessee, despite multiple statutory notices under Section 142(1) of the Act, served electronically and physically, had failed to come forth with any explanation regarding the deposits made in her bank account during the subject year

Geethala Tejaswini, Hyderabad vs. Income Tax Officer, Ward-15(1), Hyderabad

Appeals of the assessee are allowed for statistical purposes in terms of our aforesaid observations

ITA 322/HYD/2025[2013-14]Status: DisposedITAT Hyderabad18 Jul 2025AY 2013-14

Bench: Us:

Section 142(1)Section 144Section 147Section 148Section 271(1)(c)Section 68

return of income in compliance to notice under Section 148 of the Act, dated 30.03.2024 nor complied with the notices issued under Section 142(1) of the Act, therefore, the A.O., after validly putting the Geethala Tejaswini, Hyderabad. assessee to notice, proceeded with to frame the assessment to the best ... under Section 148 of the Act. Also, it was observed by him that the assessee, despite multiple statutory notices under Section 142(1) of the Act, served electronically and physically, had failed to come forth with any explanation regarding the deposits made in her bank account during the subject year

Sandeep Perneti, Nellore vs. ITO., Ward -1, Gudur

ITA 226/HYD/2025[2017-18]Status: DisposedITAT Hyderabad18 Jul 2025AY 2017-18

Bench: Us :

For Appellant: Shri Abhishek Murali, C.AFor Respondent: Shri Pavitran Kumar J. Sr.DR
Section 142(1)Section 147Section 148Section 69Section 69A

submitted by him that he had filed his return of income for the subject year on 19.04.2021. 4. The A.O. issued notice under Section 142(1) of the Act, dated 10.03.2022, calling upon the assessee to furnish the requisite details, viz. (i). source of income; (ii). copy of profit

Madasu Rambabu, Uppugundur vs. ITO, Ward-1, Ongole

ITA 242/HYD/2023[2017-18]Status: DisposedITAT Hyderabad18 Jul 2025AY 2017-18

Bench: Us:

Section 142(1)Section 147Section 148

verified by him, therefore, the same was held by the A.O. as a non-est return. 5. The A.O. issued notice under Section 142(1) of the Act to the assessee, calling for certain information. In compliance, the assessee furnished requisite details. Also, it was submitted by the assessee that

Madasu Rambabu, Uppugundur vs. ITO, Ward-1, Ongole

ITA 241/HYD/2023[2013-14]Status: DisposedITAT Hyderabad18 Jul 2025AY 2013-14

Bench: Us:

Section 142(1)Section 147Section 148

verified by him, therefore, the same was held by the A.O. as a non-est return. 5. The A.O. issued notice under Section 142(1) of the Act to the assessee, calling for certain information. In compliance, the assessee furnished requisite details. Also, it was submitted by the assessee that

Ashok Kumar Agarwal and Ors HUF, Kolkata vs. A.C.I.T., Circle - 34, Kolkata

In the result, the appeal of the assessee is allowed

ITA 1/KOL/2025[2017-2018]Status: DisposedITAT Kolkata18 Jul 2025AY 2017-2018

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Ashok Kumar Agarwal & Ors Huf Acit, Circle 34, C/O S.N. Ghosh & Associates, Aaykar Bhavan Poorva, Advocates 2, Garstin Place, 2 Nd 110, Shanti Pally, 7 Th Floor, Vs. Floor, Suite No.203, Off Hare Eastern Metropolitian By Pass, Street, Kolkata-700001, Kolkata-700107, West Bengal West Bengal (Appellant) (Respondent) Pan No. Aaeha8352F Assessee By : Shri Somnath Ghosh, Ar Revenue By : Shri Amuldeep Kaur, Dr Date Of Hearing: 20.05.2025 Date Of Pronouncement: 18.07.2025

For Appellant: Shri Somnath Ghosh, ARFor Respondent: Shri Amuldeep Kaur, DR
Section 142(1)Section 143(2)Section 68

IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, KOLKATA BEFORE SHRI RAJESH KUMAR, AM AND SHRI PRADIP KUMAR CHOUBEY, JM

Mohammed Sajid Khan, Kolkata vs. I.T.O., Ward - 40(1), Kolkata

In the result, the appeal of the assessee is partly allowed for statistical purposes

ITA 2442/KOL/2024[2015-2016]Status: DisposedITAT Kolkata18 Jul 2025AY 2015-2016

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 142(1)Section 143(1)(a)Section 147Section 148Section 250

आयकर अपीलीय अधिकरण कोलकाता 'बी' पीठ, कोलकाता में IN THE INCOME TAX APPELLATE TRIBUNAL KOLKATA ‘B’ BENCH, KOLKATA श्री जॉजज

Subbiah Subramani Venkatesh, Chennai vs. ITO, Ncw-6(1), Chennai

In the result, both the appeals filed by the assessee are allowed for statistical purposes

ITA 1316/CHNY/2025[2015-16]Status: DisposedITAT Chennai18 Jul 2025AY 2015-16

Bench: Shri S.S. Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./I.T.A. No.1316/Chny/2025 िनधा"रण वष"/Assessment Year: 2015-16 Subbiah Subramani Venkatesh, Vs. The Income Tax Officer, Old No. 157, New No. 14, Non Corporate Ward 6(1), Sanjeevarayan Koil Street, West Chennai. Mambalam, Chennai 600 021. [Pan:Avups4151M] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Hitesh, Advocate For Shri D. Anand, Advocate ""थ" की ओर से/Respondent By : Ms. V. Supraja, Addl.Cit सुनवाई की तारीख/ Date Of Hearing : 16.07.2025 घोषणा की तारीख /Date Of Pronouncement : 18.07.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi:

For Appellant: Shri Hitesh, Advocate for Shri D. Anand, AdvocateFor Respondent: Ms. V. Supraja, Addl.CIT
Section 142(1)Section 144Section 147Section 148Section 148ASection 69A

assessee made cash deposit of ₹.77,20,510/- in his bank account of ICICI. There was no compliance to various notices issued under section 142(1) of the Act and show-cause notices issued under section 144/142(1) of the Act. Accordingly, the Assessing Officer treated the cash deposits

Vellaikannu Rajagounder Subramaniam, Vellore vs. ITO, Ward-3, Vellore

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 1307/CHNY/2025[2017-18]Status: DisposedITAT Chennai18 Jul 2025AY 2017-18

Bench: Shri S.S. Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./I.T.A. No.1307/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 Vellaikannu Rajagounder Vs. The Income Tax Officer, Subramaniam, No. 4, New Street, Ward 3, Thirunagar, Gandhinagar, Vellore. Vellore 632 006. [Pan:Abtps6539A] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Abhishek Murali, C.A. (Virtual) ""थ" की ओर से/Respondent By : Ms. V. Supraja, Addl.Cit सुनवाई की तारीख/ Date Of Hearing : 16.07.2025 घोषणा की तारीख /Date Of Pronouncement : 18.07.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 21.06.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2017-18. 2. We Find That This Appeal Is Filed With A Delay Of 248 Days. The Assessee Filed An Affidavit For Condonation Of Delay Stating The Reasons. Upon Hearing Both The Parties & On Examination Of The Said Affidavit

For Appellant: Shri Abhishek Murali, C.A. (virtual)For Respondent: Ms. V. Supraja, Addl.CIT
Section 131Section 133(6)Section 142(1)Section 144Section 69A

Nagar Branch during demonetization period and did not file return of income for AY 2017-18. Thus, the Assessing Officer issued notice under section 142(1) of the Act dated 17.01.2018 requiring the assessee to file return of income, but, however, the assessee did not comply with the same. However ... response to the notice under section 142(1) of the Act, the assessee filed return of income on 22.08.2018 after the expiry of time stipulated in the notice and thus, the Assessing Officer treated the ROI as invalid. After examining the bank statement obtained under section

Kongu Welfare Trust, Villupuram vs. ITO, Exemptions Ward-1, Chennai

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 1298/CHNY/2025[2018-19]Status: DisposedITAT Chennai18 Jul 2025AY 2018-19

Bench: Shri S.S. Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./I.T.A. No.1298/Chny/2025 िनधा"रण वष"/Assessment Year: 2018-19 Kongu Welfare Trust, Vs. The Income Tax Officer, No.2/1, Vijayapuram Iind Street, Exemptions Ward 1, Chinnasalem – Tk, Villipuram, Chennai. Villupuram 606 201. [Pan:Aactk2793E] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Mudit Bohra, Advocate ""थ" की ओर से/Respondent By : Ms. V. Supraja, Addl.Cit सुनवाई की तारीख/ Date Of Hearing : 16.07.2025 घोषणा की तारीख /Date Of Pronouncement : 18.07.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 20.03.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2018-19. 2. The Assessee Raised 6 Grounds Of Appeal Amongst Which, The Only Issue Emanates For Our Consideration As To Whether The Ld. Cit(A) Is 2

For Appellant: Shri Mudit Bohra, AdvocateFor Respondent: Ms. V. Supraja, Addl.CIT
Section 10Section 12ASection 142(1)Section 143(3)Section 164(2)Section 2(15)

Income Tax Act, 1961 [“Act” in short]. The return was selected for complete scrutiny and the Assessing Officer issued notice under section 142(1) of the Act along with questionnaire. The assessee has reported voluntary contribution forming part of corpus ₹.2,70,000/- . The assessee also shown receipts