u/s 132 of the Act and therefore such a surrender cannot amount to voluntary surrender and Date of Judgment 21-06-2018, ITA No.501/2017 The Pr. Commissioner of Income Tax CIT(A) & another Vs. M/s Deccan Mining Syndicate Pvt. Ltd. 10/18 the Assessing Authority was justified in imposing penalty under Section 271[1][c] of the Act, rejecting the explanation