PADAM KUMAR JAIN,RANCHI vs. DCIT, CENTRAL CIRCLE-1, RANCHI

In the result, all the appeals filed by the assessee are allowed and copy of common order passed is to be placed on respective case files

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

71 Assessee has only stated that he had surrendered the additional sum with a view to avoid litigation, buy peace and to channelize the energy and resources towards productive work and to make amicable settlement with the income tax department. Statute does not recognize those types of defenses under the Explanation 1 to section 271(1)(c). It is true