Penalty provision altered: removal of 'without reasonable cause' increases sanction risk unless disclosure and tax payment during search occur. Penalty provision is amended by removal of the phrase 'without reasonable cause,' expanding penalty scope. Taxpayers who cannot substantiate items must prove their explanation is bona fide and that all facts material to income computation were disclosed; the proviso to Explanation 1 is omitted. Undisclosed income found in a search will not attract penalty if recorded in books or disclosed to the tax authority before the relevant date, or if the taxpayer, during the search, admits acquisition from undisclosed income, specifies its derivation, furnishes the return within statutory time limits and pays tax with interest.
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Penalty provision altered: removal of "without reasonable cause" increases sanction risk unless disclosure and tax payment during search occur.
Penalty provision is amended by removal of the phrase "without reasonable cause," expanding penalty scope. Taxpayers who cannot substantiate items must prove their explanation is bona fide and that all facts material to income computation were disclosed; the proviso to Explanation 1 is omitted. Undisclosed income found in a search will not attract penalty if recorded in books or disclosed to the tax authority before the relevant date, or if the taxpayer, during the search, admits acquisition from undisclosed income, specifies its derivation, furnishes the return within statutory time limits and pays tax with interest.
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