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Penalty under section 271AAB remained leviable on undisclosed cash found during search because the disclosure was made only after seizure and admission under section 132(4), so the assessee could not escape penalty merely because the returned income later matched the finally assessed income after quantum relief. The Tribunal held that clause (a) was inapplicable because the assessee did not specify or substantiate the manner of deriving the income, clause (b) was inapplicable because the income had in fact been admitted, and the case therefore fell under clause (c). As no extraordinary circumstances justified the maximum rate, the penalty under clause (c) was restricted to 30% of the undisclosed income.
Penalty under section 271AAB remained leviable on undisclosed cash found during search because the disclosure was made only after seizure and admission under section 132(4), so the assessee could not escape penalty merely because the returned income later matched the finally assessed income after quantum relief. The Tribunal held that clause (a) was inapplicable because the assessee did not specify or substantiate the manner of deriving the income, clause (b) was inapplicable because the income had in fact been admitted, and the case therefore fell under clause (c). As no extraordinary circumstances justified the maximum rate, the penalty under clause (c) was restricted to 30% of the undisclosed income.
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