In the result, both the appeals filed by the assessee are partly allowed for statistical purposes
Bench: Shri Manomohan Das & Shri Rakesh Mishra
263 CTR 1 (SC)[30-10-2013], wherein it has been held that voluntary disclosure does not relieve the assessee from the mischief of penal proceeding u/s 271(1)(c) of the Act. Thus, in the case of the assessee, the penalty was liable to be levied as per the provisions of sub-section