Penalty for failure to disclose wealth: reasonable-cause defence introduced, stricter disclosure and substantiation requirements follow. Section 18 is amended to delete the words 'without reasonable cause' and to add a proviso allowing no penalty in specified clauses where the person proves reasonable cause. Explanation 2(B) now requires that failure to substantiate must be accompanied by inability to prove the explanation is bona fide and that all facts material to net wealth computation were disclosed; its proviso is omitted. Explanation 5 is replaced to require assets be recorded in books or disclosed to the Commissioner before the relevant date, or be declared during the search with details of acquisition and payment of tax with interest, followed by furnishing the net-wealth return.
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Provisions expressly mentioned in the judgment/order text.
Penalty for failure to disclose wealth: reasonable-cause defence introduced, stricter disclosure and substantiation requirements follow.
Section 18 is amended to delete the words "without reasonable cause" and to add a proviso allowing no penalty in specified clauses where the person proves reasonable cause. Explanation 2(B) now requires that failure to substantiate must be accompanied by inability to prove the explanation is bona fide and that all facts material to net wealth computation were disclosed; its proviso is omitted. Explanation 5 is replaced to require assets be recorded in books or disclosed to the Commissioner before the relevant date, or be declared during the search with details of acquisition and payment of tax with interest, followed by furnishing the net-wealth return.
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